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HomeMy WebLinkAbout12-7635McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUH2E - ID # 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association 10790 Rancho Bernardo Road San Diego ,California 92127 v. Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania 17011 `: ~~, _ ._ ., a a _. ~. ~ ....! L~_. ` ,_~~-~ _, ~.... Attorneys for Plaintiff ._ ....~ ` -• Cumberland County Court of Common Pleas Number Ja - ~~ CiVi 1 lera- COMPLAINT IN MORTGAGE FORECLOSURE `~./ /03.75 Ap A~ ~#~~9~0 9 ~~a~yy7g F~~ie ~ ss~zb ~a~~ ~ NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20} days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that ifyou fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAhE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOLK WITH INFORMATION ABOUT HIRING A LAWYER. IF ~'OU CANNOT AFFORD TO HIRE A LAWYER, 'CRIB OFFICE MAY BE ABLE TO PROVIDE ~'OU WITH INFORMATION ABOUT AGENCIES THAT MAY' OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania. 17013 (800)990-9108 AVISO Le hen demandado a usted en la come. Si usted quiere defenderse de ester demandas ex-puestas en las paginas siguientes, usted tiene veinte (?0) dial de plazo al partir de la fecha de la demanda y la notificacion. Race falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defenses 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 continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con lodes las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADOINMEDIATAMENTE. SI USTEDNO TIENE A UN ABOGADO, VA A O TELEFONFA LA OFIC[NA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. S( LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMATION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO Nl NINGUN HONORARlO. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania 17013 (800}990-9108 r~ie # ss9?h Pace 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Unless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgment that we obtain. Upon Your written. request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle Cumberland County !~ ile # X8926 Pace 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMorgan Chase Bank, National Association, duly organized and doing business at the above-captioned address. 2. The Defendant is Jeremy Runkle a/k/a Jeremy M. Runkle, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/11er last-known address is 204 Deanhurst Avenue, Carnp Hill, Pennsylvania 17011. 3. On September 25, 2002, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems Inc., as nominee for Gateway Funding Diversified Mortgage Services, L.P. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1775, Page 2581, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 4. On November 12, 2010, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems [nc., as nominee for Gateway Funding Diversified Mortgage Services, L.P. to JPMorgan Chase Bank, N.A., as Acquirer of Certain Assets and Liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation Acting as Receiver, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Book Instrument No. 201035739, such Assignment of Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 204 Deanhurst Avenue, Camp Hill, Pennsylvania 1701 1. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due May 1, 201 l and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default. in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. Hie # ss9~h Page 4 ~. The following amounts are due on the mortgage: Principal Balance $ lO1,444.0 Interest from April 1, 201 ]through November 30, 2012 $ 11,201?0 Late Charges $ 1 13.34 Attorney's Fee $ 1,60.00 Escrow Advance $ 5,819.42 Property Preservation $ 1 gg 77 Property Inspections $ X43 00 GRAND TOTAL $ 120,6>9.78 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff s sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. Notice of Intention to Foreclose as required by Act 6 of 1974 (4l P.S. y40 ~) and notice required by the Emergency Mortgage Assistance Act of ] 983 as amended under 12 PA Code Chapter l3, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested required. A copy of Chase's Homeowner Information Packet is attached hereto as Ehhibit "B. " WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $120,659.78, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. [ ] T~.R ENCE J. McCAB ,ESQUIRE [ ARC S. WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET CAIRO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ]MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff r~ie # ss9zh Pace ~ VERIFICATION J T C d/1 ~ ,hereby states that~e she is ~_'~e ~~,S~~G~ `]/ of JPMorgan Chase Bank, National Association, Plaintiff in this matter, that~e she is authorized, to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of is er 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. Name: S,~F ~ai~ f~E~7~7` DATE: ~Q~ -/ J -~~ Title: (/rCE ~ E S/O' E~ Name: JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle r~it a ss9?~ Page 6 ;: Exhibit' A F[RST AMERICAN TITLE INSURANCE CO. ,W. Commitment Number: RUNK242-02R SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the westem line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No, 264 and the eastern line of Lot No. 261 forty (40) feet to point on the southern line of Lot No. 265; thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths (137.97) feet to a point in the west side of Deanhurst Avenue; thence southwardly along the westem side of Deanhurst Avenue on hundred (100) feet to a point, the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35. See also Pian recorded on July 10, 1956 in Plan book 8, Page. I Certify this to be recox3ed In Cumberland County PA ~_, ~., s ' " ~'` {) o t;' ~:,~~ ` '°° Recorder of Deeds AITA Commitment Schedule C (RUN K242-02R.PFDlRUNK242-02R14) B« 1775PG2595 ~("i~~ You may save the form locally to your computer and complete at your own pace. Chase can NOT accept electronic signatures on these documents, so it's important that you print the document and sign in all required places. Defay:; in the process often are a result of missing information or signatures an required forms. This packet contains the foGowing items: Section 1. Required Documentation for Borrower and Co-Borrower Checklist - Detailed list of the documents you must send to us in addition to the packet Section 2. Financial Information Form- Provides information about your property, loans, income, etc. Section 3. Home Affordable Modification Program Hardship Affidavit - Explainsthe circumstances that have made it difficult for you to stay up-to-date with your mortgage payments Section 4.4506T-EZ Request for Transcript of Tax Return Form - Allows Chase to receive a transcript ofyour tax return to verify income information if you need any assistance completing this packet please contact us at 866-550-5705. Please send the completed packet as weft as alt required documentation to Chase: By Regular Mail: Chase Fulfillment Center P.d. Box 469030 Glendale, CO 80246 By Overnight Mail: Chase Fulfilment Center 4500 Cherry Creek Drive South Suite #i00 Glendale, Cfl 80246 Fax: 866-282-5682 important information Chase Home Finance LLC is attempting to collect a debt, and any ~formatfon obtained wilt be used for that purpose. we may report information about your account to credit bureaus, late payments, missed payments, or other defaults an your account may be reJeeted !n your credit report. 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 It you are currently a debtor in bankruptcy proceedings and subject to the protections of the automatic stay, or if you have received a finat discharge in a bankruptcy, this notice is for comppance and/or informatbnal purposes only and not an attempt to Impose personal Uabillty for the debt In vlolatlon of the bankruptcy taws. However, Chase Home Finance LLC still has the right under the Mortgage to foreclose on the Property. An important reanfnder for all our customers: As stated in the "questions and Answers for Borrowers about the Homeowner AffordabiUty and stability Ptan" 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 !n advance." Chase offers loan modlflcatlon assistance free of charge {i,e., no modification fee required). Please stall us Immediately at 866-S50-s705 to discuss youc options. The longeryou delay the fewer options you may have, fl765H Cf'S C'JR-10-c'3-p9-CF In order for us to evaluate your request you must aampiete the enclosed packet, in full, and tax ter mail ft to Chase with the required daaumentatian. Bcrr.e ~~xr(=;F rd.=rne. ~~ ~~'~+vner t ~ upierJ ~ _~ Vcn r7ianer Gciupied ~~CT~~}N 1: Required Documentation for Borrower and Co-Borrower If yc~u are= ~ Wage Earn+=r ~yo«,, receive a W-2 from your employer} please use the followin;; checklists ~ ~ Tbuc {21 =oat re'rr'nt Pay t~hs f*.v.o 6cr ~aeh bnrro~er) i 7 ~ i ~;th tilt ~ r nh .ur~~t En~ploye'~ Borrower Year(s):__~ I~#anfhts}: _ Ca B ,craw.: 1 ea isj. Mop Ihis;, __ ~ ~ h t re ~ s, a ~e ; o. ~th's c ~ ompt to 9ank',itatemern (must prav~c4e ati pages! ' ~ h~ ,;, =c nt start 3u =it{s} supporting a sets listed on page 2 of the fir~andat lnfarr; iatfan Fnrrm (rn~tst provide ati paps .~ of statement,; ~ h st rep wnE; rax Rert=rn t_ornpieied {signed wi[fi ati pages) or most recent 4iied,3nd proo(oF extensten {signed wstit ~.(t pages) } °rgof or li ~u- ?c ft r rsther nit .eh~~ld fnernbers Uvine in the home (Alinx~ny, 'tsild 3up;u~rt, Pensicrt etc.) !'r you v , uch i~ ~ rime consi9ered for a loan workvut i I i F't~y;t of ;-.y other h~~«+~ie received (Aiur pony, Rental, Child Support, Pension, etc.) ~ i s L ro ~.' of urt~ .r= a n: <er't ut~iity Di ~-~ your rsa , i ~,t property a ldress ~ f I C. 3i; I I Or CCU hl () r i.i~py tf e ~n s recF~ni property tax :,dt(s~ vnth a copy ai the canceled deck for alt ap~piicabte taxes (County, City, ~cM'rtx7i, etc.) 3, t-opy ~~ r"e u. rant insurance zleciaration page Fay all app(itahle coverage types {oust show pi err,ium amount ro. homeww s. -s, ~`tno f r c ewird Frcc~ i ' i,ay~ nor-_ ~f lien eotstnetr's . ssariatian Fees (if api,~ikabEe) f=!r.»;-ii v.r.~t C?ccu,l:d (~;~NL'{} A) Rental Inco;ne wigs cosies of P,entai Agreerrsent B) Prit~cipat, inCerest_'f ,xers, and Insurance ir.,r Primary Res(dence 5 .----- --_ __.__.n..,_.....__.._~ ...,,_,... _~ _.. _-. C hlcrtpage Fiolr."ors) (or PrGnary kesidence --- ~ - D; Printery Res(deree r~dttre.ds (inxae~elow} I ~ t~ornpletec Firtanc;.~~ lnfa:ma[ion Form tenctoseci ~~ c:rsrpL~ t:•rr Haresh p s!ht,avit (enclosed,! -completed and signed oy at! Burrowers {na notary required) c:arripleted 450b ~ -E~ - Reques*. for Transcript of Tax Return (exlosed.) Be sure to sign and date this ~orrn. --- f you are: Self Emi?foyerl, please use the fallowing checklists P ~ L 5t a~ men? 1 huel+ted or reviewed YTD Income Statement (must pro~ridel '~ most rea st t,ve Z5 r 3rs' ~{'ax iteturr~< Completed (personal a:~d business, signed with aIt pages] or 1099s w mast recent Twin (t} years iileJ and ,~rooi of extens on tasl iur ~ 4} rriurtt s ,:` aaratptete Business and Personal Bank Statements {roust provide alt pages. li a busdness account is not use;:; i?rc~~r:c ; ~ruitten statem,~nt sta;inF a !nisiness account is not used i-,, ~ lust recent statement{s} supporting assets listed on page Z of the Ftnan[lai lrrformation Forrr~ (must provide all pages. If a busmen, ~tcc s~ is clot +ased, ~sros-i•t;e a vd'iEters statement stating a business account is not used. ` ~_~ ~ ~iGSt re i stcb°rne pporting assets listed on page 2 of thr Finantiat Infornt+atia=i Forrr (r.i .'. p:rovirie all pages of statet~ser~es) 7 ~ c,~f?th ~ t ~~ ~ ct E . .>ss n,,~<~ersr<ip: Borrower Years}~__, Month(sl __ t;c,-Fiorrower Yearjs;: Month(s)._.. - -- -- ~_ (r:~~`::;f re f ,~ ,er ~o~rsehoid n~iernt~ers living in the game iAlimary, Child Suppcrt, Peres€or» rate.] - ~'; ~- ,,h ~ c rye ~_osisidered fur a Loan workout I r~~ui c:~P ~ >1h<rr 1 rne received (rtilirnony, Ren_at, Chifd Support, Per 4on, etc) L~ Pre of c1 ; rp;3ricy ~ recant t~ti`,;ty bill -n your namt~ of property address ~~ It it];fin ~S I`lv'rt i~ :. „ . . a) Copr ni Clio me ~ t;:ent pn;perty tare !`aril(s) with a Copy of the canceled check for at(appiicabte taxes (County, City, school, etc.; R, Copy ui tre ccrrcnt insurance declarat"sorr page Far aU apptirrbie coverage types (must show prer~iiurn amount fur #u~meowner s ;nod it ;; »vi,re) t ; ~'ror,f r ~n I~~cnrrestiner'sA,tsor_iatiun Fees; ('rfapplica~le} PJ;n-l~+n'~ r C~tJi~' ~ r :eirtal l ,r ;t r up;es a(Rertitai ,v;?reemeni 4',*inc=- , i _st x+-.~, ar°d Insurance for Primary Resider~~ 4 i j M^-tF ~ r I_,- 'p, ~~i;r 3ry 3esSderu~~ ~.~ ~--- ~) r'r ~~ ~ -~ 'i ... 1dd~ ass rinpc~t bet:.,. ~~ ~~ Ccrnptet~sd non _~i in?crrrnati;xr a`onr~ (erFClosedj `~ Comp{etr E :rrJs7ii, Ftiidadit (cr.?losed completed ono signed by alt Borrowers (rto notary requiree} ( ~~ ComhEecrJ r1E.7_ E Kequest for TYansu~pt of Tax Return (enclosed.} $a sure to sign and date this firm. ","rnYa~„ts F: t<;a~t N ~rn~er ~inanci~l Infor~~i~~a ~~ar-~s Raga 7 of 3 BORROWER 1~FQRM%~;t~iUl~l' - ___ .._..._...._.~._____. _..,-~ .,~ _ -..a. ~._ __ __ _.~ e n ltrs optKSrs Ear rc sotwng IVSfr iwme 10an issue. iNease answer r e u~c i0n5 beltrtiv at Imo ! ly nd s r ~ t , a ~: -.... _..... -'1 ~__,..-- ~... _ m _ I ; .n isticc, will or~ty be urea ~ ~s aM in the evaluation xrf ho. ~,e„v rK .t ~„ ~rrcvnratlnn f,~~rt,.,. .,,~ r, . ,,,.. _ H ~. .._ _ _.....- .- ~urrnwr~r - - ..._...r _.-. ~ GG-B OV1i6l . _~.__ . ._.....-_._.-~ __. r N, ~; e vita: 1! r ~ ~7 r t1 i[3Fa°L ' ~:~ Pi: n~.. ;I(xEr:d@,l„ a# $r. It a~bpUCd~le~ ~ ,..-- Suu tl SF' !r y nr, erltrer 5oUai Secttr3ty '~,~mher ~ ~ ~~ i~lcxne ~hcr~: . _ Be,i Tirrte its CtttL .~......__...._...._.._.~.._,_.._. .,.... _..._._____.~ _. -- w _~._...._.,~.,. 4-soma Phone. ---~ Bast T,nx So t.,a_t ...._._~ vy'v'4rk Pt'a(1i': Qa52 (ime tZl C.ati: .,..~,_..~..,..r...._...,.,~.,~.,...... irlork I}hAn1.: ~(?}s ~rr$e [Z, t. ~tli •.IT,Y-.•,..m.,«.•,,...--.,., P__. -, t)2 ictt 1>txrmi~ flat Tirpe to t;alt; ._-.r,.~. e.....,... ....,.,- ....-e-v.._,. C.rttfCr nhonr'-' kfn.,r I Irrre '.t7 ? ..t .....,, , ~ E-r,~i1 Ae9dtes5 t ._ _ - _.._ ...._.._._.-._.,._--- -_ _ ~-mail Address 3 " P~a'n~} ion t+~ ~cl at ~p .....--.-. ___ _ - ct >f~ t t +a~? ~ Yr q ~ R!O .,,. _,. _....~e~ ,..~..~.. .~._.~...,...~ ._..- _ 7 R@lnl!5SNYq trJ I~oatAlY Vta B-rxtait, ~ YeS ~~ Nr,~ ~ I riarit`t ;talus ___ ~ '~ tbrnaa,rit'1'1 ~ Mar~ripra ~ Sepa*ated ~ bhrprred ---~ _ .____..~..-_. _ Marital Status ~_~ U~marr;e ; ~ Di ed ~~ ~epar r J~ ~ ~ ~arri vorc to ed -_~ ~ ~_ PRQP.~R,TYlN~O.RMA7'~flN _ .._......~.~..._._...,,~ ...,.,~ '. Pry; rtv Ad.lres i ,t Far. c t, s:.ate & zl cudel ~ ~ Melt#ng Adu''e55 ~S[ 86t, ~ )~, state. & 21p OUe t '-"""" i Reside a Prop? iv? Want to Retain Property? ~ ~ Borrnwer # of People ,n Household: tt of Dependents. E~ C Borrower i ~ Yes ~ N o r__ ~' cf Units at Pr t Prot' eriy Condition Es the Property #ar Sate7 ~rr" luting AmnunC _----- --woad ~` 1 Fair Poor --- },FS No ~?ealtor Name Realtor Address Reatt~r Pnone+ ~.,....-_.~ ..W.~ .e. .__ € -son Acr,sunt Nur, __ ftr ~~ ~ rv.,.. ol. . -,~ __.._._, be! I Months Past flue: Second loan Accotimt ht;rmber: Second Loan Months Past C?ue: ~Pal;an~„ ~- , ....... ____.___._ _.,_ ~ .__.,._._ .. _,r._..__,._...___...._._,._m._ _..... ,..~~ .. ~ ~.,. _. -__.. prevention cesotutitrn~ l.J va' ~ ~ h?a ~NhiIch fc~~eaosure resolutior as at.-eady ~J Refinance ~ ~ [)r ff me nt ~ hasn As r late , ~ ~ .°__ ~,__ ____ Oe ed-i n-[. fe u _.`____ _.v .. .._ -.. _. . __T __ __. ff you are in an active f3atKrui Areyo~~ rtrt;vti3~n4r,iptr,~ ;_~ Yes ~~ No Modlticatton ~ Repayrnen2 Plan I__W~ Sh<>rt 5ale Chase r,~~suciatr Phone we will need to work with your attorne on a possible rpsotution. Bankruptcy Chapter Tyne Bank ,st.rtty Ca.c Number Earkru t,.f ~=ssocc; ^ i~aart`E-_' ~ 6aniLruptcyAt.torneyAddress Borrawer_ _____ E 1p(C}Pr Ernpfo;r r Ad~.7ess __._~ L r r r,to} e r C~ i ~, r~ ~~: 1 i o.v to.ig em p;oyed? _ ._- _ ,. C v Err ~slr e !~' y Nr rusr,yage ~ampany: Ga&e ProceSS Began Dater ~ani:r.+pKy Filing _..._~ ~._._.j ~tocrPy,,hturz "~Ntv.ftMATlf?N __ _. _:._...~ -_. _ ..~_. _w.: ._..~ _ Ca-Bmrrawar Ernpiayer Empic~yer~ g6drttss Employer f~hone: 1 riow ong .rn;:(oyudt }r l# Ertipt€ ,c.lt ~ . Y,,3 k No -...., 1. _~ C'HCiCkko--U;fiS ~H~~ uorr~,~er Nairne f c,;}n 'vurn~c~r ---- _,..... Borrower Ir,~ ante 5c~ ai cfa Mor?thty Gross Income ~Er7r~oyci ~~larn2 ~ortt~al, etcj Finaneial Information f=orm Page2of3 Ca-Borrower trunme Source yer Blame, Rental, etcl j Monthly Gross income Frr~plc;yer ~ Emp{Dyer 5r~~plcye= __ . ~ S ' Employer Employer ~ i Employar _ _., Re ita! .nccme ~ S Rental Income i t ties t ~ ther - Otnrr r~t31 s _ ___..__._.^_.._ ?otaf _ .,n ,.._ ...,..,_.~...._..,... _,_ ~..~..._ . _ ____ T A. _ _ Additional Income Description Borrower C Alimony, child support, or separate maintenance Income need not 6e revealed if Co-Borrower Borrower or Co-Borrower does not choose to haue it considered for approval of a loan workout. A~; t Nome t~i tflf.'r `{edI `S to tt.._.-_- i(tC;~{EI'rt~-tt F,rr t~s Env> t rcn s ~ C?tcch n~ Balance .. n.. `;awngs Balance ~ - C)thcr - Jtho - _ _ _. ~*i~r Ta*.al Monthly Amount Amount Owed Value Vehicle ~ ~~ 1~lodel(Year A nt 'a d j ~ Autornob,te ~ mou l we _ _._.._ _ _ Value .......... _ __......._. _._._ -j _ __._. ~ .___. AUtOmCbllP __....~..._.~ t ,._...-....._..._.____. .~_.~__~_ v S Automobile _.., ____. $ < S 5 Motorcycle ~ __ _ _.___._ _ __ ._ _. $ 5 Boat ..... ._.__..___.__.__..___ ._~_ ..~.__. - 5 _____.., ,_.. -- _ S S c '; __, _._. , ._ Motor Nome - -_... ..__.....___.- . _.------ ._ i s ' ~ Airplane _ -_..,-.~_..___ ' ~ S Other: __ u^ tl cr .__..._. _. .--- - ... --_-_ .__ _. S ~ 5 ~ c > > Total Ct ~C=CFIr-J5179 ~F-IA~ ~ ~ SECTION 3; Home Affordable Modlficatlon Program Hardship Affida4rgC Borrower Ram,e (first, middle, lastj: Co-Borrower l~aRle (firs 1, middle, last): Property Street Acdres: Property City, State and cif': Services: Loan iVumber~ date of 8irtf•:: C+ate of Hirttr 1 In order to qualify for _____ ,________ ~_ _~~ ~ ,~ ,s ("Services"} offer to enter into an agreement to modify my loan under the federal government's Home Affordable Modification Program (the "Agreement"), Ilwe amlare submitting this form to the Services and indicating by mylour checkmarks l"X"}the one ar more events that Contribute to mylour difficulty making payments on my/our mortgage loan. Borrower Co-Harrower Yes Nu Yes No My income has been reduced or lost. For example: unemployment, underemployment, reduced job ^ [_~ C! [_~ hours, reduced pay, or a decline in self-employed business earnings, I have provided details under "Explanation" {page 3}. Yes No Yes 'Jo My household financial circumstances have changed, For example: death in family, serious or chronic [_; _. ^ illness, permanent or short-term disability, increased family responsibilities {adoption or birth of a child, taking care of elderly relatives ar other family members). 1 have provided details under "Explanation° {page 3}. Yes No Yes No My expenses have increased, For example: monthly mortgage payment has increased or will increase, ^ ^ ^ ~~ high medical and health-care costs, uninsured tosses (such as those due to fires or natural disasters}, anexpectediy high utility bills, increased real property taxes. I have provided details under "Explanation" (page 3). Yes `1<; Yes Nr,• My cash reserves are insufficient to maintain the payment on my mortgage [oan and C~vpr basil: [~, ^ ^ ^ living expenses at the same time. Cash reserves include assets such as cash, savings, money market funds, marketable stocks or bonds (excluding retirement accounts}. Cash reserves do not inClr~de assets that serve as an emergency fund (generalEy equal to three times my rncnthiy debt payments}. i have provided details under "Explanation" {page 3}. '(es to Yes No My monthly debt payments are excessive, and t am overextended with my creditors, t may have used ^ ^ [ j (~ credit cards, home equity loans or other credit. to make my monthly mortgage payments. i have provided details under "Explanation" (page 3). `res i`Jo Yes !'~~ f°nere are other reasons I/we cannot make our mortgage payments. l have provided details under [_] [__] ^ _~ '°Explanation" (page 3}. Page 1 of 4 HIFAI•f-U9t7~ FGflll ~'6N'~~ ;~ I '' ~' i ~ha~rt Form ~egt~est fog Ir>Idivrdu~i! Tax t~ett~r~a Trans~r~~ ~(7,~'rrner 2')0~'; ~;, tiB ~Qn. tS4Y27 i4 oenartmerc c si .rea;my ~ Y Request may not be processed if the farm rs Incarnplete ar rrreg3ble. mtrr~ia' Revni r,: to Tip: use F;>r,r. ~506T-EZ to oEder a 7040 sees,=s tax re[um transcript free of cha« xe 1 + ^famf he+~.vn a~~ fax return, if a joint return, enter the name shawra first 7.a (, ajora;. return, er~ferspouse~s Warne shown on tax return !^ r'IrSi30f:tal 5et:Urity ntltilber Un 9aX t'e#urn ab Secand racial security number ifjaint tax return 3 current name, actdre~s ;including apt., rnom, or suite na.), city, state, and iIP Cade Previ~'n~, adrfresti ho'rvn an the Iasi return fEed if different from line 3 ~, l tl~e transcrpt is to oe maned to a third party {such as a mortgage company), enter the thins party's name, address, and telephon > numbe . the '' IRy i7a, no cr>>jt ~cd over vrhat Ehe third party+joes with the tax infarmation, Th rd party r+arne Telephone number Crease Fuitillment Center r gl3g) 55C-5705 . -_ .r._.._ _ __._~._..___.~ - ___._.,...~...._.~...._,......._ v...m.____.... ____. luidress (inchtdiry apt, raom, or suite no.l, city, state, and ZIP code ---------__.-__~_, ~ecuiar IVicih P.O. Bax 469030, Glendale, CO 80246 ~lvernicht ~~lai{T4500 Cherry Creek Ori~Je Sauth, Suite 100, Glendale; CO 80246 _~~_...,.~ _a_e.. _.W_..m ___._._- _..__.m 5 Year(s) requested. Enter t-~e year(s} of the return transcript you are requesting (for example, "2QQ8"). Most requests wtll he ;roc sled within 1 U business days, 20fl8 ~Cautron. If the transcript is be<ng mailed to a third party, ensure that you have fi0ed in fine 6 before signing.5ign and date the forr;5 crK.r yarn heue filled in line es C~:lmpletir~g these steps helps to protect your privacy. Note, if thelk5 is unable ±olncate a return that matches the taxpa;~eridentlty lnformarton prov;ded above, orifi~'Srecords indicate that the return has nc,t bccr+ friee; the It?5 may no?ify you or the third party that +t was unable to locate a return, or that a return was not t7fed, whicfaever 15 eppltcotrie. .______W.__._~.~ .............N,,,...~. _...... .._..._..._~ Signature of iaxpayer(s}, I d?dare that 9 am either the taxpayer whose name is shown on Tine 1 a car 2a. If the request applies to a joint turn, either husband or wifrz must si.#r;. Note, ti its tor'nt rnusi be re~.-eiv~d .r~ithin 60 days ofsignature date. / Signature tree instructipns) Sign Here s~r,,,ss'~ sryraatare 7e}ephone rwrntrer ~~{ taxpayer on line to or2a i ) Rate .-__---. _.__..-_,_ ----- Usle Fnr Privacy Act and Papeawork Reducilon Act Notice, see page 2. Cat. Pdo. 5a t85S Fcrm as'o~r-ea. (tt~-ZOOS! FORM 1 JPMorgan Chase Bank, National Association Plaintiff VS. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant IN THE COURT OF COMMON PLEA- OF., CUMBERLAND COUNTY, PENNS~~:VIA f...~ ~n.i 1 ,~ ~ f r+i ~L~ ~~(1 -.... z~' Y ~a- 11Y~ C1V11 t--i -1 - ._ _ . _ c- ~_. ... _.._ --, NOTICE OF RESIDENTIAL MORTGAGE FORECLOS~JRE 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM I5 FREE. Respectfully subm' ed: ^^~~ ~~ D, t`e ~ I ~'~- [S nature of Counsel for P intiffJ McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CD KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 C BRIAN T.LAMANNA,ESQUIRE-ID#310321 `O � ~±T ANN E.SWARTZ,ESQUIRE-ID#201926 M CD- - JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 - -� Philadelphia,Pennsylvania 19109 r.., (215)790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY ` Plaintiff COURT OF COMMON PLEAS V. Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Jeremy Runkle a/k/a Jeremy M. Runkle, in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal $ 120,659.78 Interest from 12/01/12 to 03/22/13 $ N/A Total $ 120,659.78 McCABE,WEISBERG AND CONWAY,P.C. Ild BY: [ ]Terrence J. cCabe,Esq. [ ]Marc S. Weisberg,Esq. [ ]Edward D.Itonway,Esq. .(.']'Margaret Gairo,Esq. [ )Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ J Kevin T.McQuail,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ J Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian, Esq. Attorneys for Plaintiff AND NOW,this day of 144ri I ,2013,Judgment is entered in favor of Plaintiff,JPMorgan Chase Bank,National Association,and against Defendant,Jeremy Runkle a/k/a Jeremy M.Runkle,in rem only and not in personam,and damages are assessed in the amount of$120,659.78,plus interest and costs. 416,5D PD AIT1 BY T ROT OT 0*18C-53ri 01, aa8483 MeCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Jeremy Runkle a/k/a Jeremy M.Runkle, is not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C.App.§501,et seq.;and that the Defendant,Jeremy Runkle a/k/a Jeremy M. Runkle, is over eighteen(18)years of age,and resides as follows: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 McCABE,WEISBI qtG AND CONWAY,P.C. SWORN AND SUBSCRIBED— "n BY: BEFORE ME TH, — Tefrencel.McCabe,Esq. Marc S.Weisberg,Esq, 43 -Margaret Gairo,Esq. Edward .Conway,Esq. OF 20 Andrew L.Markowitz,Esq. Heidi R.Spivak,Esq. Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. OF PUB Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff N C3 TA 0i-fA­­--"'--'— L 91 E;k L *w-*"I Aklic coy of F&jj##b6k ftm l Department of Defense Manpower Data Center Results as of:Mar-22-2013 07:00:54 SCRA 3.0 4D +s.m"Aeplut Pttik'gua t to Sm—vicen mibe d Civil Relief Act Last Name: RUNKLE First Name: JEREMY Middle Name: M. Active Duty Status As Of- Mar-22-2013 n , NA NA a ,��. b NA This response Data 4r 4 W M t .,^ 1 .. r Active fluty start Dab FP This response reAacts - it "l I'm ys preps Status Date k } NA w.,m ,�„Yom' NA u x' This reapers-reflects whether ..tgdf has �rePoK for active duty Upon searching the data banks of the Department of Defense ManpoweP 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. )6t s lot.& A er 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 the enforcement of the Servicamembers 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.mil"URL http://www.defenselink.miVfaqtpis/PC09SLDR.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(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. Ail 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)(I). 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: Y29DN9A3EOA13EO McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Jeremy Runkle a/k/a Jeremy M.Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,P.C. BY: BEE MET DAY [ ]Te a ce J McCabe,Esq. [ ]Marc S. Weisberg,Esq. OF 13 [ )Edward Conway,Esq. [- )'Margaret Gairo,Esq. [ )Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak, Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. NOTAR PUB [ )Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ )Ann E. Swartz,Esq. [ ]Joseph F. Riga,Esq. IV D TA R I A L E q t [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Barbara J. Alb -Notoy Public: Attorneys for Plaintiff City of Philab"ja,RIB fawns .'q CORM PON cJ1P►RES JAN:12,2014 Al McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S, WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH L FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,P.C. BY: BEFORE ME TH1 DAY Ter;ence J abe,Esq. Marc S.Weisberg,Esq. Edward 4Conway,CM'Cocrn Esq. 1,-TUargaret Gairo,Esq. OF 1*13 Andrew L.Markowitz,Esq. [ Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. [ Kevin T.McQuail,Esq. Christine L.Graham,Esq. [ Brian T.LaMantia,Esq. P BLI Ann E.Swartz,Esq, [ Joseph F.Riga,Esq. Joseph I.Foley,Esq. Celine P.DerKrikorian,Esq. Attorneys for Plaintiff 1GkY0fPh1iladn1!-' W(V MAMMON ORRES JAN.'12,201 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of IS PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE,WEISBERG AND CONWAY,P.C. BY: lw'o [ ]Terre PY,e,Esq. { ]Marc S. Weisberg,Esq. [ ]Edward D. Esq. f TMargaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. { ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq, [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse,Carlisle,Pennsylvania 17013 Curt Long Prothonotary March 11, 2013 To: Jeremy Runkle aWa Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 JI'Morgan Chase Bank,National Association Cumberland County vs. Court of Common Pleas Jeremy Runkle a/k/a Jeremy M. Runkle Number 12-7635 Civil Term NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO,DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y FOR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS You ACT WITHIN TEN(10) EscRiTo CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED R13CLAMOS FORMULA= EN CONTRA suyo. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERTY AMON DESIDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS, NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTE V OIR PREUBA ALOUNA,DICTAR DO NOT HAVE A LAWYER,00 TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED,PODRIA PERDERBIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOTAFFORD TO HIRE A LAWYER,THIS OFFICE MAY BEABLE INMEDIATAMENTE. St USTED NO TIENE A UN ABOGADO, VA A 0 10 PROVIDE YOU WITH INFORMATION ABOUTAGENCIES THAT MAY OFFER TELErONEA LA OFICINA EXPUSO ABAjo.ESTA OFICINA LO PUEDE LFGAI,SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, PROPORCIONAR CON INFORMAC16N AcrRCA DE FMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTEDNOPurrxPROPORCIONAR PARA EMPLEARUNABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DE LAS AGENCIASQUEPUEDENOFRECERLOS (800)990-9108 SERVICtOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 McCABE WEISBERG AND CONWAY,P.C. BY: &j�E hU44,,i Terrence J#AcCabe,Esquire Marc S.Weisberg,Esquire Edward MlConway,Esquire [.}'Margaret Gairo,Esquire Andrew L.Markowitz,Esquire [ ]Heidi R.Spivak,Esquire Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire Ann E,Swartz,Esquire [ ]Joseph F. Riga,Esquire Joseph I.Foley,Esquire Attorneys for Plaintiff dbm h� , A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Jeremy Runkle a/k/a Jeremy M.Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothon X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe. Weisberg and Conwav P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA µ CIVIL DIVISION FILE NO.: 12-7635 Civil Term Civil Term �v JPMorgan Chase Bank,National Association c-) V. AMOUNT DUE: $120,659.78 3 Z '� ^p Jeremy Runkle a/k/a Jeremy M.Runkle INTEREST: from 03/23/13 � r•n $3,708.21 at$19.38 c�is� N oQ ATTY'S COMM.: o _4 C Cp =0 _1t COSTS: =CD _ r; TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishees)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Signature: Firm: MCCABE,WEISBERG ANP C NWAY C-S TERRENCE J.McCABE,ES"E a MARC S.WEISBERG,ESQUIRE �( J EDWARD D.CONWAY,ESQUIRE '73, 00 CO- MARGARET GAIRO,ESQUIRE ANDREW L.MARKOWITZ,ESQUIRE HEIDI R.SPIVAK,ESQUIRE MARISA J.COHEN,ESQUIRE !i 44 K VIN T.MCQUAIL,ESQUIRE Vr . CHRISTINE L.GRAHAM,ESQUIRE n l�l BRIAN T.LAMANNA,ESQUIRE ?CA ANN E.SWARTZ,ESQUIRE JOSEPH F.RIGA,ESQUIRE JOSEPH I.FOLEY,ESQUIRE CELINE P.DERKRIKORIAN,ESQUIRE Address:123 S.Broad Street, Suite 1400 Philadelphia,PA 19109 Attorney for: Plaintiff `~ Telephone: (215)790 1010 w ' • LEGAL DESCRIPTION ALL THAT CERTAIN track of land situate in the(Borough of Camp Rill,County of Cumberland and Mate of Penrlsytvania, bounded and desk as Mors,to vrit: BEGINNING at a point on the westem line of Deanhurst Avenue and on the northern line of Lot Polo.267 of the'herehafter mentioned Plan of Lots,thence along said northern lip of Lot No.267 vastwardly one hind sixteen and seventy-eight hundredths J116.78)feet to a point on the eastern line of Lot No.264;thence northvrardly along the eastern line of Lot'No.264 and the eastern line of lot No.261 'forty(40)feet to point on the southern aline of Lot No.265; thence in an,eastedy direction one hundred thirty-seven and ninety-seven hundredtts(137.97)feet to a point in'the west ode of Deanhurat Avenue;titenoe southvrardly*r@ the western side of vRstem side of Deanhurst Avenue one hundred t100j feet to a point,the place of BEGINNING. BEING No.266 on the Pb of Chaff Place as recorded in the Cumberland County Recorders Mee in Plan Book 2, Page 69,and as corrected by subuVe nt Plan of a portion thereof recorded in Cumberland County in Pk�n book 6 Page 35.See also Plan recorded.on July 16„1956 in Plan book 6,Page. Being the same pro eq acquired by Jeremy M.Runkte,by Deed recorded 1010212002,of record in Deed Book 253, Page 428D,in the Oftioe of the Recorder of Umbedand County,Penns ftnia. RB5678 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011. BEING the same premises which HAROLD J.BATSCH AND MARION BATSCH H/W AND BARBARA ANN TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated September 25,2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 1775,Page 2581,granted and conveyed to Jeremy Runkle a/k/a Jeremy M.Runkle in fee. TAX MAP PARCEL NUMBER: 01220533050 McCABE,WEISBERG AND CONWAY,-P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 --t HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 wry C:) o BRIAN T.LaMANNA,ESQUIRE-ID#310321 t'- ANN E.SWARTZ,ESQUIRE-ID#201926 C--) ' JOSEPH F.RIGA,ESQUIRE-ID#57716 C ct:? JOSEPH I.FOLEY,ESQUIRE-ID#314675 �r 3� 123 South Broad Street,Suite 1400 �� .C- Philadelphia,Pennsylvania 19109 ` 215 790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MFRS"Mortgage Electronic P.O.Box 2026 Registration Systems,Inc Flint,MI 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,PA 19034 Orrstown Bank 427 Village Drive Carlisle,PA 17015 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of-Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia, PA 19107 Commonwealth of Pennsylvania 6th Floor,Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department.of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales, United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S. Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address NONE I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. �.e May 8,2013 TERRENCE J.McCA ,E QUIRE DATE MARC S.WEISBERG UIRE EDWARD D.CONWAY,ESQUIRE MARGARET GAIRO,ESQUIRE ANDREW L.MARKOWITZ,ESQUIRE HEIDI R.SPIVAK,ESQUIRE MARISA J.COHEN,ESQUIRE K,EVIN T.MCQUAIL,ESQUIRE HRISTINE L.GRAHAM,ESQUIRE BRIAN T.LAMANNA,ESQUIRE ANN E.SWARTZ,ESQUIRE JOSEPH F.RIGA,ESQUIRE JOSEPH I.FOLEY,ESQUIRE CELINE P.DERKRIKORIAN,ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp hill,County of CuMedand and State of Pennsylvania, bounded and described as follo�msl to wit. BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of'Lot No.267 of the hereinafter mentioned Plan of Lots;thence along said northern line of Lot No.267 va*ardly one hundred sixteen arrd seventy-eight hundredths(116.78)feet to a point on the eastern line of Lot No.264;thence norlhwardiy aging the eastern line of Lot No.264 and the eastern line of Lot No.261 forty(40)feet to point on the southem line of Lot No.265; thence in an easterly direction one hundred tt-seven and ninety-seven hundredths(137.97)feet to a point in the west side of Deanhurst Avenue;thence southwady allong,the Awtem side of western We of Deanhurst Avenue one hundred (I DO)feet to a point,the place of BEGINNING. BEING No.266 on the Plan of Chartiers,Place as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 69,and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35.See also Plan recorded on July 10,1956 in Plan book 8,Page. Being the same property acquired by Jeremy M.Runkle,by Deed recorded I R2002,of record in Deed Book 253, Page 4780,in the Office of the Recorder of Cumberland County,Pennsylvania. RB5678 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011. BEING the same premises which HAROLD J.BATSCH AND MARION BATSCH H/W AND BARBARA ANN TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated September 25,2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 1775,Page 2581,granted and conveyed to Jeremy Runkle a/k/a Jeremy M.Runkle in fee. TAX MAP PARCEL NUMBER: 01220533050 z McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 CD CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 r-3 BRIAN -' BRIAN T. LaMANNA,ESQUIRE-ID#310321 -vim ANN E.SWARTZ,ESQUIRE-ID#201926 Q t= JOSEPH F.RIGA,ESQUIRE-ID#57716 CD JOSEPH 1.FOLEY,ESQUIRE-ID#314675NCD o 123 South Broad Street,Suite 1400 3:29b T Philadelphia,Pennsylvania 191.09 7;1 C1 (215)790-1010 Cs . CIVIL ACTION LAW y - v JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Jeremy Runkle&Wa Jeremy M. Runkle Number 12-7635 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jeremy Runkle a/k/a Jeremy M.Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Your house(real estate)at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$120,659.78 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 canceled 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,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway, P.C.,Esquire at(215)790-1010. 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 on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the 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 schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 M LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hilt,County of Cumberland and State of Peana}lvania, bounded and descrbed as follows,to M. BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of lot No.257 of the hereinafter mentioned Plan of Lots;thence along sad northem line of lot No.267 vreshvardly one hundred sWeen arrd seventy-eight hundredths(116.78)feet to a point on the eastern line of lot No.254;thence northwardly along the eastern line of Lot No.264 and the eastern Ime of lot No.,251 forty(40)feet to point on the southern line of Lot No.265, thence in an easterly direction one hundred thirty-seven and ninety-seven hundredth(137.97)feet to a point in the vet side of Deanhurst Avenue;thence southy/ardly along the hiestem side of western side of Deanhurst Avenue one hundred (100)feet to a point,the place of BEGINNING. BEING No.265 on the Pin of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 69,and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35.See also Plan recorded on duly 10,1956 in Plan book 8,Page. Beim the same property acquired by Jeremy M.Runkle,by Deed recorded 10f0212002,of record in Deed Bonk 253, Page 4280,in die Office of the Recorder of Cumberland County,Pennsylvania. RB5678 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011. BEING the same premises which HAROLD J.BATSCH AND MARION BATSCH H/W AND BARBARA ANN TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated September 25,2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 1775,Page 2581,granted and conveyed to Jeremy Runkle a/k/a Jeremy M.Runkle in fee. TAX MAP PARCEL NUMBER: 01220533050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7635 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 JEREMY RUNKLE AWA JEREMY M.RUNKLE (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: $120,659.78 L.L.: $.50 Interest FROM 3/23/13-$3,708.21 AT$19.38 Atty's Comm: Due Prothy: $2.25 Atty Paid: $221.75 Other Costs: Plaintiff Paid: Date: 5/20/13 David D. Buell,Prothonotary (Seal) -�Ct'1/fLl t Deputy REQUESTING PARTY: Name: CHRISTINE L. GRAHAM,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No.307169 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM, ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 c a ANN E. SWARTZ,ESQUIRE-ID#201926 --- -� zz' i JOSEPH F. RIGA,ESQUIRE-ID# 57716 m co � .'.! JOSEPH 1. FOLEY,ESQUIRE-ID#314675 'Z� G-) CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 -<> cry 123 South Broad Street, Suite 1400 `-n Philadelphia,Pennsylvania 19109 ''' � Tj C) 215 790-1010 °`' JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 25th day of July, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBER A NWAY,P.C. BEFO ME THI� DAY BY: [ ]Terrence J.McCab ,Esqu arc S. isberg,Esquire OF ,2013 [ ] Edward D.Conway,Esquire [ ]Margaret airo,Esquire VLAndrew L. Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ J Kevin T.McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire NOTARY PUBLI [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire �flM E H pF y NIh [ ]Joseph 1.Foley,Esquire [ ]Celine P. DerKrikorian,Esquire N O TA R I A!_ 3 C A L Attorneys for Plaintiff Bai$ara J. Voyer.Notary public C*of Philadalpttia,Phiiadelphia Court, MY COMMISSION EXPIRES JAN.12,201,1 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY, ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE- ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE- ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE.-ID#307169 CHRISTINE L. GRAHAM;ESQUIRE-ID# 309480 BRIAN T.LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE=ID# 57716 JOSEPH 1. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1. The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address File#58926 Page 1 Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MERS"Mortgage Electronic P.O.Box 2026 Registration Systems,Inc Flint,MI 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,PA 19034 Orrstown Bank 427 Village Drive Carlisle, PA 17015 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 427 Village Drive Carlisle,PA 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 File#58926 Page 2 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept. of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address NONE File#58926 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. July 25,2013 McCABE,WEISBE ND CONWAY,P.C. DATE BY: [ )Terrence J.Mc ate,Esquire rc S.Weisberg,Esquire [ ]Edward D. Conway,Esquire [ ] argaret Gairo,Esquire Andrew L.Markowitz,Esquire [ Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire ]Kevin T.McQuail,Esquire [ ]Christine L. Graham,Esquire )Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P. DerKrikorian,Esquire Attorneys for Plaintiff Re: JPMorgan Chase Bank,National Association v.Jeremy Runkle a/k/a Jeremy M.Runkle.et al. Cumberland County;Number: 12-7635 Civil Term File#58926 Page 4 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term Defendant DATE:July 25,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Jeremy Runkle a/k/a Jeremy M.Runkle PROPERTY:204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $120,659.78 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Check type of mad or service: U.S.POSTAGE>>PITNEY BOWES Xddress of Sender Name and ❑Certified ❑Recorded Delivery(International) McCabe,Weisberg and Conway,P.C. 0 COD 0 Registered 123 S.Broad St.,Suite 2080 ❑Delivery Confirmation ❑Return Receipt for Merchandise Philadelphia,PA 19109 ❑Express Mail ❑signature Confirrnaeon ATTN:K.Keller-58926 0 Insured ZIP 19109 02 1VY $ 020.40' Line Abc]cN=ba Postage 0001377494 JUL 25 2013 JPMorgan Chase Bank, "MERS"Mortgage Electronic National Association Registration Systems,Inc Plaintiff P.O.Box 2026 Flint,MI 48501-2026 V. Jeremy Runkle a/k/a Jeremy M.Runkle Defendant 2 Gateway Funding Diversified Mortgage Services,L.P. 500 Office Center Drive Suite 325 Fort Washington,PA 19034 3 Orrstown Bank 427 Village Drive Carlisle,PA 17015 4 Tenants/Occupants 427 Village Drive Carlisle,PA 17015 5 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 6 Inheritance Tax Office 110 North W'Street Suite#204 Philadelphia,PA 19107 7 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor,Strawberry Square Department#280601 Harrisburg,PA 17128 • 8 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O.Box 8486 Harrisburg,PA 17105-8486 9 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 10 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 11 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg,PA 17128-1230 ATTN: Sheriffs Sales 12 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 13 Domestic Relations Cumberland County P.O.Box 320 Carlisle,PA 17013 14 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 15 Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 16 United States of America c/o Atty General of the United States U.S.Dept.of Justice,Rm 4400 950 Pennsylvania Avenue,NW Washington,DC 20530 17 United States of America c/o Atty General of the United States U.S.Dept.of Justice,Rm 5111 950 Pennsylvania Avenue,NW Washington,DC 20530 Total Number of Pieces Listed by Sender 0.111Hd 17 ^0 L 9y y r � o •; ti ggg7 NO SHER'IFF'S OFFICE OF CUMBERLAND COUNTY _ Ronny R Anderson rf Sheriff 'r. - THE FRo i He Triii' �4��rtiLr of+�turtbr� 4 Jody S Smith 6 X11'' 2913 AUG 29 Pry 2: 20 Chief Deputy ' Richard W Stewart IVIIIERLAND CQUNTY Solicitor OFFICE OFTRE Sw-6RIFF PENNSYLVANIA JPMorgan Chase Bank, National Association Case Number vs. Jeremy Runkle AKA Jeremy M. Runkle 2012-7635 SHERIFF'S RETURN OF SERVICE 07/05/2013 06:15 PM -Deputy Shawn Harrison, 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 204 Deanhurst Avenue, Camp Hill Boro., Camp Hill, PA 17011, Cumberland County. 08/01/2013 11:54 AM- Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jeremy Runkle but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 204 Deanhurst Avenue, Camp Hill, PA 17011, Defendant could not be located prior to expiration date, 9 service attempts were made. 08/28/2013 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: $915.51 SO ANSWERS, August 28, 2013 RON R ANDERSON, SHERIFF 1 (_o 5b P 3 (c)CcuntySuite Sheriff,Teleosoft,Inc. McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCt.J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff J MARL S. WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 3441.9 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at:204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in.the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MFRS" Mortgage Electronic P.O.Box 2026 Registration Systems,Inc Flint,MI 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,PA 19034 Orrstown Bank 427 Village Drive Carlisle,PA 17015 5. Name and address of every, other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA .17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address NONE I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. X May 8,2013 TERRENCE J.McCA",EPQUIRE DATE MARC S.WEISBERG UIRE EDWARD D.CONWAY,ESQUIRE MARGARET CAIRO,ESQUIRE ANDREW L.MARKOWITZ,ESQUIRE HEIDI R.SPIVAK,ESQUIRE MARISA J.COHEN,ESQUIRE I�EVIN T.MCQUAIL,ESQUIRE yCHRISTINE L.GRAHAM,ESQUIRE BRIAN T.LAMANNA,ESQUIRE ANN E.SWARTZ,ESQUIRE JOSEPH F.RIGA,ESQUIRE JOSEPH 1.FOLEY,ESQUIRE CELINE P.DERKRIKORIAN,ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in theFBorough of Camp Hill,County of Cumberland and State of Pennsylvania, bounded and described as follows,to vAt.- BEGINNING at a point on the western line of Deo-1hurst Avenue and on the northern line of Lot No.267 of the hereinafter mentioned Plan of Lots;thence along said north,am line of Lot No.267 westwardly one hundred ctdeen and seventy-eight hundredths(116.78)feet to a point on the eastern line-of Lot No.264;thence northwardly along the eastern line of Lot No.264 and the eastern line of Lot No..261 forty(40)feet to pdni on the southern line of Lot No.265-, thence in an easterly direction one hundred firty-seven and ninety-seven hundredths(137.97)feet to a point in tie last side of Deanhurst Avenue;thence south%ardly along.the western side of western side of Deanhurst Avenue one hundred (10O)feet to a point,the pine of BE-GINNING. BEING No.266 on the Plan of Chartiem,Place as recorded in the C-urnbeedand County Recorder's Of in Plan Book 2, Page 69,and as corrected by subsequent Plan of a portion thereof recorded in Cumbed3nd County in Plan book 6 Page 35.See also Plan recorded on July 10,1956 in Plan book 8,Page. Being the some property acquired by Jeremy M.Runkle,by Deed recorded I RK2002,of record in Deed Book-253, Page 429,in the Nee of the Recorder of Cumberland County,Pennsylvania. RB5678 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011. BEING the same premises which HAROLD J.BATSCH AND MARION BATSCH H1W AND BARBARA ANN TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated September 25,2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 1775,Page 2581,granted and conveyed to Jeremy Runkle a/k/a Jeremy M.Runkle in fee. TAX MAP PARCEL NUMBER: 01220533050 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jeremy Runkle a/k/a Jeremy M.Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Your house(real estate)at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 1.0:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$120,659.78 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 canceled 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,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 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 on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the 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 schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 .. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows,to gait: BEGINNING at a pint on the western line of Deanhurst Avenue and on the northem line of tot No.267 of the hereinafter mentioned Plan of Lots;thence along said northern line of Lot No.267 westwardly one hundred sixteen and seventy-eight hundredths,(116.78)feet to a point an the eastern line of tot No.264;thence northwardly along the eastern line of Lot No.264 and the eastern line of tot No.261 forty(40)feet to point on the southern line of Lot No.265, thence in an easterly direcbn one hundred thirty-seven and ninety-seven hundrodtlz(137.47)feet to a point in the West side of Deanhurst Avenue;thence soutllmardly along the western side of westem side of Deanhurst Avenue one hundred (I DO)feet to a point,the place of BEGINNING. BEING No.266 on the Plan of Ghartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page fig,and as corrected by subsequent Pfan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35.See also Plan recorded on July 10,'1956 in Plan book 8,Page. Being the same property acquired by Jeremy M.Runkle,by Deed recorded 102002,of record in Deed Book 253, Page 4284,in the Office of the Recorder of Cumberland County,Pennsylvania. RB5678 204 Deanhurst Avenue, Camp Hill,Pennsylvania 17011. BEING the same premises which HAROLD J.BATSCH AND MARION BATSCH H/W AND BARBARA ANN TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated September 25,2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 1775,Page 2581,granted and conveyed to Jeremy Runkle a/k/a Jeremy M. Runkle in fee. TAX MAP PARCEL NUMBER: 01220533050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7635 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 JEREMY RUNKLE A/K/A JEREMY M.RUNKLE (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: $120,659.78 L.L.: S.50 Interest FROM 3/23/13-$3,708.21 AT$19.38 Atty's Comm: Due Prothy:$2.25 Atty Paid: $221.75 Other Costs: Plaintiff Paid: Date: 5/20/13 David D. Buell,Prot ono ary (Seal) g Deputy REQUESTING PARTY: Name: CHRISTINE L. GRAHAM,ESQUIRE Address:MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No.307169 TRUE COPY FROM RECORD In Testimony whereof,'I here,unto set my hand and the seal of said Court at Carlisle,Pa This DO day of -~Prothonotary AL On May 28, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA, Known and numbered as, 204 Deanhurst Avenue, Camp Hill, as Exhibit"A" filed with this writ and by this Reference incorporated herein. Date: May 28, 2013 By: " Real Estate Coordinator R 1 l LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012-7635 Civil Term RB5678 204 Deanhurst Avenue, Camp Hill,Pennsylvania 17011. JPMORGAN CHASE BANK, BEING the same premises which NATIONAL ASSOCIATION HAROLD J. BATSCH AND MARION VS. BATSCH h/w AND BARBARA ANN JEREMY RUNKLE aka TAYLOR AND NANCY ELIZABETH LAUBACH JT by deed dated Septem- Jeremy M.Runkle ber 25,2002 and recorded October 2, Atty.:Terrance McCabe 2002 in the office of the Recorder in ALL THAT CERTAIN tract of land and for Cumberland County in Deed situate in'the Borough of Camp Hill, Book 1775,Page 2581,granted and County of Cumberland and state of conveyed to Jeremy Runkle a/k/a Pennsylvania,bounded and desribed Jeremy M. Runkle in fee. as follows,to wit TAX MAP PARCEL NUMBER: BEGINNING at a point on the 01220533050. western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; hence along said northern line of Lot No. 267 westward one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastern line of Lot No. 264; thence northward along the eastern line of Lol No. 264 and the eastern line of Lot No. 261 forty (40) feet to pdnt on the southern line of Lot No. 265;thence in an easterly direction one hundred thirty seven and ninety- seven hundredths(137.97) feet to a point in the west side of Deanhurst Avenue;thence southward along the western side of western side of Dean- hurst Avenue one hundred(100)feet to a point,the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 2,Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan book B,Page. Being the same property acquired by Jeremy M. Runkle, by Deed re- corded 10/02/2002, of record in Deed BOOK 253, Page 4280, in the Office of the Recorder of Cumberland County,Pennsylvania. 92 V PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. Lisa Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this day of August, 2013 Notary NO'iAR1AL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 1900 Patriot Drive t4e atr1*otwXews Mec�li anicsburg, PA 17050 Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2012-7MChAlTerm This ad ran on the date(s)shown below: JPATIONAL ASSOCIATION 07/28/13 g Vs. J.SEMY RUN KLE A(K/A Jar y 08/04/13 M,Runkle £' Arty: Terrance McCabe 08/11/13 ALL SAT ER"tract of land situate in the Borough of Camp Hill, County of cumberland and state of Pennsylvania, " " " " " " " " ' " ' " " " " " " " " bounded and described as follows, to wit BEGINNING at a point on the western line Swo to and subscribed bef a this 3 day of August, 2013 A.D.northern of Deanhurst No n7anof thehhere nafter Y g line of Lo { mentioned plan of Lots;hence along sai northern line of Lo one hundred sixteen and seventy-eight NOt ublic hundredths(116.78)feet to a point on the eastern fine of Lot No.264;thence northward along the eastern line of Lol No.264 and the eastern line of Lot No:261 forty(40)feet to a point on the southern uemctio I one hundred thence in•an easterly seven hundredths COMMONWEALTH OF PENNSYLVANIA thirty seven and ninety. Notarial Seal (137.97)feet to a pointnthe Vt side of Holly Lynn Warfel,Notary Public Deanhurst Avenue;thence southward along Washington Up.,Dauphin county the Avenue tern side hundred(loo)fee,o a point,the My Commission Expires Dec.12,2016 Avenue one hundred(100) MEMBER,PENNSYLVANIA ASSOCIATION OF NOTFtRIES place of RF.GINNING., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 12-7635 Civil Term Civil Tel*t y -, JPMorgan Chase Bank,National Association v. AMOUNT DUE: $120,659.78 t:y t Jeremy Runkle a/k/a Jeremy M.Runkle INTEREST: from 03/23/13 -0 cr $6,900.84 at$19.83 ATTY'S COMM.: + COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract, or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 204 Deanhurst Avenue, Camp Hill,Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 1 BY: viC� [ ]Terrence J.McCabe,Esq. [ arc . Weisberg,Esq. � 8.S0 s 1 [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. � CO C' 1 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. 3 '�� � [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. t 1 [ ] Christine L.Graham,Esq. [ ] Brian T. LaManna,Esq. .' "I [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. O �t << [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. It " I�Attorneys for Plaintiff g�. so .3s c141 Firm: MCCABE,WEISBERG AND CONWAY I S.7 Address:123 S.Broad Street, Suite 1400 C �bS�S� Philadelphia,PA 19109 I` -fl S1 Attorney for: Plaintiff wi.\ (A _ LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths(116.78)feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty(40) feet to point on the southern line of Lot No. 265;thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths(137.97)feet to a point in the west side of Deanhurst Avenue;thence southwardly along the western side of Deanhurst Avenue one hundred(100)feet to a point,the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2,Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan Book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan Book 8 Page. 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. BEING the same premises which JEREMY M. RUNKLE AND DAMN M. RUNKLE, HIS WIFE by deed dated September 25, 2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 253,Page 4280, granted and conveyed to Jeremy M. Runkle, married man, in fee. TAX MAP PARCEL NUMBER: 01220533050 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 -� Philadelphia,Pennsylvania 19109 'urn c ' (215)790-1010 -- JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS � cp c Jeremy Runkle a/k/a Jeremy M.Runkle Defendant NO: 12-7635 Civil Term r- y AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at:204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MERS"Mortgage Electronic P.O. Box 2026 Registration Systems,Inc Flint,Michigan 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,Pennsylvania 19034 Orrstown Bank 427 Village Drive Carlisle,Pennsylvania 17015 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff s Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the 12-7635 Civil Term District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 and U.S.Post Office and Courthouse 700 Grant Street, Suite 400 Pittsburgh,PA 15219 United States of America c/o U.S. Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.)/14a-. BY: [ ] Terrence J.McCabe,Esq. [ rc S.Weisber Esq. DATE [ ] Edward D.Conway,Esq. [ ] Margaret Gairo,Esq. [ ] Andrew L. Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T. McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T. LaManna,Esq. [ ] Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill,County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots;thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths(116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty(40) feet to point on the southern line of Lot No. 265;thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths(137.97)feet to a point in the west side of Deanhurst Avenue;thence southwardly along the western side of Deanhurst Avenue one hundred(100)feet to a point,the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2,Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan Book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan Book 8 Page. 204 Deanhurst Avenue, Camp Hill,Pennsylvania 17011. BEING the same premises which JEREMY M. RUNKLE AND DAMN M. RUNKLE,HIS WIFE by deed dated September 25, 2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 253,Page 4280, granted and conveyed to Jeremy M. Runkle,married man, in fee. TAX MAP PARCEL NUMBER: 01220533050 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 /t 1 7 F ' MARGARET GAIRO,ESQUIRE-ID# 34419 _ 7.�„ ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 ` 3 —5 pp, in HEIDI R.SPIVAK,ESQUIRE-ID#74770 C'(jNE) A 4 f MARISA J.COHEN,KEVIN T. McQUAIL,ESQUIRE RE ID#307169 PCB NS c'j v COUNT l` CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 A'Y(4 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Your house(real estate)at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on March 12,2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$120,659.78 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 canceled if you pay to JPMorgan Chase Bank,National Association the back payments, late charges,costs,and reasonable attorney's fees due. To fmd out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 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 on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the 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 schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill,County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No.267 of the hereinafter mentioned Plan of Lots;thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths(116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty(40) feet to point on the southern line of Lot No. 265; thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths(137.97) feet to a point in the west side of Deanhurst Avenue;thence southwardly along the western side of Deanhurst Avenue one hundred(100)feet to a point,the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2,Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan Book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan Book 8 Page. 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. BEING the same premises which JEREMY M. RUNKLE AND DAMN M. RUNKLE,HIS WIFE by deed dated September 25, 2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 253,Page 4280, granted and conveyed to Jeremy M. Runkle,married man, in fee. TAX MAP PARCEL NUMBER: 01220533050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7635 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 JEREMY RUNKLE A/K/A JEREMY M. RUNKLE (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: $120,659.78 L.L.: Interest FROM 3/23/13-$6,900.84 AT$19.83 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,165.76 Other Costs: Plaintiff Paid: Date: 11/5/13 David D. Buell, Prothonota (Seal) • / /OUZI-(,r- Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 • McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ, ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID# 57716 --c -rt n` JOSEPH I. FOLEY,ESQUIRE-ID#314675 rri CELINE P. DERKRIKORIAN, ESQUIRE-ID#313673 C2 JENNIFER L. WUNDER, ESQUIRE-ID#315954 LENA KRAVETS, ESQUIRE-ID#316421 =�' ' 123 South Broad Street, Suite 1400 ', Philadelphia, Pennsylvania 19109 • (215)790-1010 c' JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 4th day of February,2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBERG& CONWAY,P.C. � BEFORE ME THIS r- `�DAY By. [ ]Terrence .Mc I e,Esquire [ ]Marc S. Weisberg,Esquire OF _,2014 [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L. Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire NOTARY PUBLI [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [)4]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MAIA KUSHICK,Notary Public City of Philadelphia,Phila.County M Commission Ex t Tres M. 10,2017 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID# 316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. NO: 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. I. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File#58926 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MERS"Mortgage Electronic P.O.Box 2026 Registration Systems,Inc Flint,Michigan 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,Pennsylvania 19034 Orrstown Bank 427 Village Drive Carlisle,Pennsylvania 17015 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Camp Hill Borough 2145 Walnut St Camp Hill PA 1704 Dietterick Scott A PO Box 650 James Smith Et Al Hershey PA 17035 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor,Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 File#58926 Page 2 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America do United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept. of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#58926 Page 3 • I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. /1/ 4 McCABE,WEISBERG& CONWAY,P.C. DATE BY: [ ]Terrence J.Msatabe,Esquire [ ]Marc S.Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ] Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire I7j Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Re:JPMorgan Chase Bank,National Association v.Jeremy Runkle a/k/a Jeremy M.Runkle.et al. Cumberland County;Number: 12-7635 Civil Term File#58926 Page 4 McCABE, WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term Defendant DATE:February 4,2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Jeremy Runkle a/k/a Jeremy M.Runkle PROPERTY:204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $120,659.78 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on March 12,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. r H �Nny / ,r A w N H iTo-cn z �0ea �� .0 o�a O At C .oemo C O 0 = 0eo = 0 o E 0.' oAO fD r Jee O C 0 to 00 -1 `p m 0 f0 to z N 0 F n a e `< o 4 a ao N ❑0000c� ��a�n ►e��5"n �x; .. y 1 ►+ A W N ►+ O VI n N n z d c.° C °d� •D C Y 2 T o w - p 0 E = �3 3 n : r, 0 "' iD a ©cn-O A O C/ E. ,,., op"9'''' 14 G � -. g ... y„ � eD B u' `1 2 e•.. y • t f y bc ,. " 1 A y a d y W D "”' S'b d A Crd CD y � �O A 3 a' e >9mO„g A y t o y W y at oo Q” ZaoC p 'O „d.0 S p y ` t., 49 A0. y (� .c Q '*O A ^ om � 0 . ? . 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WEISBERG,ESQUIRE-ID# 17616 ' EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 �( t} ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009,- , r. . 11: 4 HEIDI R. SPIVAK,ESQUIRE-ID#74770 f;,� ll rsn MARISA J. COHEN,ESQUIRE-I D# 87830 v4/ 1-'' CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA, ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 10th day of February,2014, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attac -: :reto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBER ! Y,P.C. I BEFORE ME THIS t� DAY By: Terrence J.Mc •e E .o! [ ] ire [ arc S. Weisberg,Esquire OF I�,; , ,2014 [ ]Edward D., .nway, ''squire Margaret Gairo,Esquire [ ]Andrew .Marko, itz,Esquire [ ]Heidi R. Spivak,Esquire ,� [ ]Marisa J.Cohen,Esquire [ ]Christine L.Graham,Esquire I J l • r ]Brian T.LaManna,Esquire Ann E. Swartz,Esquire N u T'T7:PUB 'C ' � � [ � q [ ] q �([Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire 4 [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire :gY3.JA .a .-a-- ]Lena Kravets,Esquire tP,CLti:t:S ilnty b G p ,delp" 'Vt',� be1 1, 16 Cd1Y 'Aces GeP tem Ccxnmi McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. NO: 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M.Runkle Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Jeremy Runkle a/k/a/Jeremy M. 204 Deanhurst Avenue Runkle Camphill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Jeremy Runkle a/k/a Jeremy M. 204 Deanhurst Avenue Runkle Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein He#58926 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein "MERS"Mortgage Electronic P.O.Box 2026 Registration Systems,Inc Flint,Michigan 48501-2026 Gateway Funding Diversified 500 Office Center Drive Mortgage Services,L.P. Suite 325 Fort Washington,Pennsylvania 19034 Orrstown Bank 427 Village Drive Carlisle,Pennsylvania 17015 Orrstown Bank 77 East King Street Shippensburg,PA 17257 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Camp Hill Borough 2145 Walnut St Camp Hill PA 1704 Dietterick Scott A PO Box 650 James Smith Et Al Hershey PA 17035 Tax Claim Bureau 1 Courthouse Square, Carlise,PA 17013 Commonwealth of PA Department 280946 Department of Revenue Harrisburg,PA 17128-0946 Bureau of Compliance Attn: Sheriffs Sales 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 Deanhurst Avenue Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard File#58926 Page 2 • Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#58926 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to t I- :--,lties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. 1 J McCABE,W-EISBERG& '0 Y .C. DATE BY: [ ]Terrence J.Mc ..e,Esc' [ ]Marc S.Weisberg,Esquire [ ]Edward D.C5, way,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [S]-Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire Re:JPMorgan Chase Bank,National Association v.Jeremy Runkle a/k/a Jeremy M.Runkle.et al. Cumberland County;Number: 12-7635 Civil Term File#58926 Page 4 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Jeremy Runkle a/k/a Jeremy M.Runkle Number 12-7635 Civil Term Defendant DATE:February 10,2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Jeremy Runkle a/k/a Jeremy M.Runkle PROPERTY:204 Deanhurst Avenue,Camp Hill,Pennsylvania 17011 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $120,659.78 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on May 7,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. y eWm r r. w Id y �/- rcAn 4 w G g 0 Fit C �, � d CD T C W < V a Q 0 CD O ?� ,`".=• C/1 .1 E.3 0 ... soRA 0 7 CD•C y QQ C ►.V).i m m C 0 t&I 00 n c, GA 00 o°e IV rd fP d �p ' d z N e a 5 = i eD F n m o. a rte. D S A A w C j Q A r m > x 0 00o ❑OOOOn tnpnn� b Lill ,'n ."1. O D '� m A 5 d X 61.• C IQ A et) a. 2 QQ ~ fp C y ►d kJ 0 0 E Et 8 r► .r C e'D O.p o A Wt C , JAm.. o� �w N+ - .S 0 . O1 0 fD b 1 2 a . IN rD ONO C3 '� i 7e $6.P. N CA I A §- 3 g f. B v ;3. f` 7,; — I O O N C ONE (n o c � C 0 to I 0 4'. AO m I, w 0 I -4 8 W I z o < N CD 1 Q A O cn McCABE, WESIBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff uf 2014 114 7 PH 1: 27 P NNS A NIA COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 12-7635 Civil Term Notice of the Date of Continued Sheriff's Sale The Sheriff's Sale scheduled for May 7, 2014 at 10:00 A.M. in the above -captioned matter has been continued until July 2, 2014 at 10:00 A.M. Certificate of Filing On this date, a Notice of the Date of Continued Sheriff's Sale in the above -captioned matter was sent for filing with the Prothonotary of CUMBERLAND County. Certification of Service On this date, a Notice of the Date of Continued Sheriff's Sale was served by first-class mail, postage prepaid upon the following: Jeremy Runkle a/k 'a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania, 17011 Date:5j )1L-1 McCABE, W BY: ISBERG & CONWAY, P.C. [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esquire Attorneys for Plaintiff c S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esquire WCABE,WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J.McCABE, ESQUIRE- ID# 16496 MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID#34419 ANDREW L. MARKOWITZ,ESQUIRE- ID#28009 HEIDI R.SPIVAK, ESQUIRE- ID#74770 MARISA J. COHEN, ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 <=s t Cf)-. ` LENA KRAVETS,ESQUIRE-ID#316421 -� CAROL A. DiPRINZIO,ESQUIRE-ID#316094Q ` 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 t , JPMorgan Chase Bank,National Association Cumberland County Plaintiff Court of Common Pleas V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriff s Sale of Real Property upon the Defendant, Jeremy Runkle a/k/a Jeremy M. Runkle, at his last-known address of 204 Deanhurst Ave, Camp Hill, Pennsylvania 17011. The deputy was not able to serve the Defendant because property is vacant. Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant,Jeremy Runkle a/k/a Jeremy M. Runkle, at his last-known address of 45 West King Street, Shippensburg, Pennsylvania 17257. The deputy with property managaer who stated defendant moved over a year ago. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430,Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendants and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". 3. As a result of the investigation,a special Order of Court is required permitting service by regular and certified mail at the Defendants' last-known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. 5. No attorney has entered an appearance in this matter on behalf of Defendants and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendant,Jeremy Runkle a/k/a Jeremy M.Runkle, the Plaintiff will be prejudiced. WHEREFORE,Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Notice of Sheriff s Sale of Real Property upon the Defendant,Jeremy Runkle a/k/a Jeremy M.Runkle,by regular mail;certified mail,return receipt requested,and by posting at the last-known address of Defendants and the mortgaged premises known in this herein action as 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. McCABE,WEISBERG AND CON ,P. C. BY: [ ]Terrence J.Mkab Esquire S. Weisberg, Esquire [ ] Edward D.Conway,Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L.Markowitz,Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen,Esquire [ ] Christine L. Graham, I?squire [ ] Brian T. LaManna,Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga,Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian,Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets,Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE- ID#34419 ANDREW L. MARKOWITZ, ESQUIRE- ID#28009 HEIDI R.SPIVAK, ESQUIRE- ID#74770 MARISA J. COHEN, ESQUIRE-ID#87830 CHRISTINE L. GRAHAM, ESQUIRE- ID#309480 BRIAN T. LAMANNA, ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 CAROL A. DiPRINZIO,ESQUIRE-ID#316094 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association Cumberland County Plaintiff Court of Common Pleas V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. McCABE,WEISBERG AND CONWAY,P.C. BY: / [ ] Terrence J. McCabe,Esquire [tic S. Weisber , Esquire [ ]Edward D. Conway,Esquire [ ]Margaret Gairo, Esquire [ ]Andrew L. Markowitz,Esquire [ ]Heidi R. Spivak, Esquire [ ] Marisa J.'Cohen, Esquire [ ] Christine L. Graharn, Esquire [ ] Brian T. LaManna,Esquire [ ]Ann E. Swartz, Esquire ( ] Joseph F. Riga, Esquire [ ] Joseph I.Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ]Lena Kravets,Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 MARC S.WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L. MARKOWITZ, ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS, ESQUIRE-ID#316421 CAROL A. DiPRINZIO,ESQUIRE-ID#316094 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,National Association Cumberland County Plaintiff Court of Common Pleas V. Number 12-7635 Civil Term Jeremy Runkle a/k/a Jeremy M. Runkle Defendant CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he/she served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 5th day of June, 2014, upon the following: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Ave Camp Hill, Pennsylvania 17011 Jeremy Runkle a/k/a Jeremy M. Runkle 45 West King Street Shippensburg, Pennsylvania 17257 McCABE,WEISBERG AND CONW Y,P.C. BY: [ ] Terrence J.McCabe,Esquire [ arc S. Weis erg, Esquire [ ] Edward D. Conway,Esquire [ ] Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen,Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna,Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga,Esquire [ ) Joseph 1. Foley,Esquire [ ] Celine P. DerKrikorian,Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, 1-;squire Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE,WEISBERG AND CONWAY,P.0 / /✓�� BY: �/`'a / [ ] Terrence J. McCabe, Esquire jl�re S. Weisberg, lsquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ J Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen,Esquire [ ] Christine L. Graham, 11'squire [ ] Brian T.LaManna,Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga,Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P.DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets,Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff JPMorgan Chase Bank,National Association v.Jeremy Runkle a/k/a Jeremy M. Runkle Cumberland County;CCP;Number 12-7635 Civil Term File Number: 58926 SHERIFF'S OFFICE OF CUMBERLAND COUNTY - Ronny R Anderson Sheriff J Z � 00tH Jody S Smith Chief Deputy Richard W Stewart Solicitor •,x F;C C . ,_.,-.P JPMorgan Chase Bank, NA vs. Case Number Jeremy Runkle AKA Jeremy M. Runkle 2012-7635 SHERIFF'S RETURN OF SERVICE 01/08/2014 02:30 PM-Deputy Valerie Weary, 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 204 Deanhurst Avenue, Camp Hill -Borough, Camp Hill, PA 17011, Cumberland County. 01/31/2014 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: Jeremy Runkle a/k/a Jeremy M. Runkle, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 204 Deanhurst Avenue, Camp Hill, PA 17011, address is vacant, defendant did not leave a forwarding address with the post office. 03/10/2014 As directed by Terrance McCabe,Attorney for the Plaintiff, Sheriffs Sale Continued to 5/7/2014 05/02/2014 As directed by Terrance McCabe,Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 05/16/2014 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: Jeremy Runkle AKA Jeremy M. Runkle, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 45 West King Street, Shippensburg, PA 17257, per property manager at address stated, defendant moved out approximately one year ago. cab. SHERIFF COST: $1,445.05 SO ANSWERS, May 16, 2014 RbNlqY R ANDERSON, SHERIFF .nnhSu,i;a!herift,'r'6:11.)g4t,Inc: AFFIDAVIT OF GOOD I Jill 1111111111111111111111111111111 Jill FAITH INVESTIGATION *189767 • File#:361-0430PA Subject: Jeremy Runkle a/k/a Jeremy M.Runkle Last-known Address: 204 Deanhurst Avenue,Camp Hill,PA 17011 1 STATE OF NEW YORK IN COUNTY OF SUFFOLK ss.: Samantha Alicea,the undersigned,being duly sworn,deposes and says that I am over the age of eighteen and not a party to this action. I reside in the STATE OF NEW YORK. I conducted a good faith investigation into the whereabouts of the Jeremy Runkle a/k/a Jeremy M. Runkle at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date DueDili ence Remarks 03/12/2014 PROPERTY 204 Deanhurst Avenue,Camp Hill,PA 17011 ADDRESS: INQUIRY OF LOCAL Directory Assistance:The subject has a 03/12/2014 TELEPHONE telephone listing for the above stated last-known COMPANY: address. Search results found the number of 717 737-5256 associated with the subject. Search results show the subject resides at the 03/12/2014 INTERNET SEARCH: above stated last-known address. Search results also provided the telephone number of(717) 728-4446. 03/12/2014 DEATH RECORDS: Social Security Death Index Search was unable to locate a death record for the subject. 03/12/2014 LOCAL TAX Property Records search results were unable to IRECORD IN UIRY: confirm a mailiniz address for the subject. 1,Samantha Alicea,reviewed and signed this affidavit on 03/12/2014.The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge,information and belief. Sworn to and subscribed before me on ` �Yl� t'y?(A��,�1 Q�t J ,20� Samantha Alicea Attorney Outsourcing Support Services,Inc. LIC#1421841 I Huntington Quadrangle,Suite 2SO4 Melville,NY 11747 N�ota�ryvwulil, Firm Ref#361-0430PA MARYANNE HANLEY ~ NOTARY PUBLIC,State of New York No.01 HA6108108 Oualfied in SUFFOLK Commission Expires April 12,2016 Free people search and contact details for Jeremy M Runkle WhitePages Page 1 of 1 WhitePages.com Jeremy M Runkle Age: 40-44 Phone number 717-737-5256 Address 204 Deanhurst AveCamp Hill,PA 17011-5313 Previous locations Camp Hill,PA Anderson,IN Enola,PA ©2014 WhitePages Inc.-Privacy Policy and Terms of Use http://www.whitepages.com/name/Jeremy-M-Runkle/Camp-Hill-PA/2ssmyep 3/12/2014 Page 1 of 3 Rsearc Person Search Results Records: 1 to 25 of 29 Search Terms Used - SSN: 311-84-xxxx; Result Page: 1 2 io All Full Name Age/DOB Address Dates Phone Information 1 JEREMY K RUNKLE DOB: Feb xx, 204 DEANHURST AVE Oct 2000-Feb 2014 717.728.4446-EDT Gender:Male 1970 CAMP HILL PA 17011.5313 311.84-xxxx Age:44 LexID:2219059726 We Also ❑ Property Records ❑ Email Address Found: 2 JEREMY M RUNKLE DOB: Feb xx, 204 DEANHURST AVE Oct 2000-Feb 2014 717.728-4446-EDT Gender:Male 1970 CAMP HILL PA 17011.5313 311.84-xxxx Age:44 LeXID:2219059726 3 JEREMY MONROE DOB: Feb xx, 204 DEANHURST AVE Jun 1990-Nov 2013 717-737-5256.EDT RUNKLE 1970 CAMP HILL PA 17011.5313 Gender:Male Age:44 311.84-xxxx LexID:2219059726 i d JEREMY K RUNKLE DOB: Feb xx, 45 W KING ST Sep 2009-Jul 2013 BLUE MOUNTAIN GALLERY 11 Gender:Male 1970 SHIPPENSBURG PA 17257-1224 311.84-xxxx Age:44 LexID:2219059726 S. JEREMY M RUNKLE DOB: Feb xx, 45 W KING ST Sep 2009-Jul 2013 BLUE MOUNTAIN GALLERY Gender:Male 1970 SHIPPENSBURG PA 17257-1224 311.84-xxxx Age:44 LexID:2219059726 6 JEREMY M RUNKLE DOB: Feb xx, 62 QUEEN AVE Apr 1995-Oct 2000 717.728.4446-EDT Gender:Male 1970 ENOLA PA 17025.2339 311-84-xxxx Age:44 LexID:2219059726 7 JEREMY K RUNKLE DOB: Feb xx, 62 QUEEN AVE Mar 1995.Oct 1999 717.728-4446-EDT Gender:Male 1970 ENOLA PA 17025-2339 311-84-xxxx Age:44 LexID:2219059726 JEREMY K RUNKLE DOB: Feb xx, 172A ERFORD RD Apr 1994-Feb 1999 Gender:Male 1970 CAMP HILL PA 17011.1807 311.84-xxxx Age:44 LexID:2219059726 https:Hsecure.accurint.com/app/bps/main 3/12/2014 Page 2 of 3 9 JEREMY M RUNKLE DOB: Feb xx, 172A ERFORD RD Apr 1994-Feb 1999 717-728.4446-EDT Gender:Male 1970 CAMP HILL PA 17011.1807 311.84-xxxx Age:44 LexID:2219059726 10. JEREMY M RUNKLE DOB:Feb xx, 1920 E 7TH ST APT N1 Jun 1993-Jan 1999 Gender:Male 1970 ANDERSON IN 46012.3546 311.84-xxxx Age:44 LexID:2219059726 11 JEREMY K RUNKLE DOB:Feb xx, 3121 YALE AVE APT May 1993-Aug 1996 717.728-4446-EDT Gender:Male 1970 CAMP HILL PA 17011.5253 311.84-xxxx Age:44 LexID:2219059726 12. JEREMY M RUNKLE DOB: Feb xx, 3121 YALE AVE APT May 1993-Aug 1996 717-728.4446-EDT Gender:Male 1970 CAMP HILL PA 17011.5253 311.84-xxxx Age:44 LexID:2219059726 13. JEREMY K RUNKLE DOB:Feb xx, 3135 FLETCHER ST APT 8 Nov 1992.Oct 1995 Gender:Male 1970 ANDERSON IN 46016.5371 311.84-xxxx Age:44 LexID:2219059726 14.� JEREMY M RUNKLE DOB:Feb xx, 3135 FLETCHER ST APT 8 Nov 1992.Oct 1995 642-0075 Gender:Male 1970 ANDERSON IN 46016.5371 311.84-xxxx Age:44 LexID:2219059726 I I ............_............_......_._.__-_...._....._._....___._—..____....---......._._...._..........______—_._—_._.__-__........... __._.....__........_.___..._._..........__.._..._.---.......____...__._..._...._._....___......------------..______...._.... JEREMY K RUNKLE DOB:Feb xx, 172 ERFORD RD APT A May 1994 717-728-4446-EDT 115' Gender:Male 1970 CAMP HILL PA 17011.1807 311-84-xxxx Age:44 LexID:2219059726 — JEREMY M RUNKLE DOB: Feb xx, 172 ERFORD RD A – May 1994 717-728.4446-EDT _ ! 16� Gender:Male 1970 CAMP HILL PA 17011-1807 311.84-xxxx Age:44 iLexID:2219059726 I _ F 7. JEREMY K RUNKLE DOB:Feb xx, 1807 E 6TH ST Jul 1992-Jan 1993 Gender:Male 1970 ANDERSON IN 46012-3530 311.84-xxxx Age.44 L"ID:2219059726 1$ JEREMY M RUNKLE DOB:Feb xx, 1807 E 6TH ST Jul 1992-Jan 1993 642-0075 Gender:Male 1970 ANDERSON IN 46012.3530 311.84-xxxx Age:44 LexID:2219059726 https://secure.accurint.com/app/bps/main 3/12/2014 Page 3 of 3 19. JEREMY K RUNKLE DOB: Feb xx, 5480 E 525 S May 1992 Gender:Male 1970 WOLCOTTVILLE IN 46795.9461 311.84-xxxx Age:44 LexID:2219059726 20._ JEREMY M RUNKLE DOB: Feb xx, 5480 E 525 S May 1992 Gender:Male 1970 WOLCOTTVILLE IN 46795.9461 311.84-xxxx Age:44 LexID:2219059726 21 JEREMY K RUNKLE DOB: 1970 W 1920 7TH E 4 N Aug 1991-Dec 1991 Gender:Male Age:44 ANDERSON IN 46012 311.84-xxxx LexID:2219059726 22. JEREMY M RUNKLE DOB: Feb xx, PO BOX 611 Sep 1988-Dec 1991 642.0075 Gender:Male 1970 ANDERSON IN 46015.0611 311.84-xxxx Age-44 LexID:2219059726 2 3 JEREMY K RUNKLE DOB: 1970 RT PO 67 Aug 1991 Gender:Male Age:44 WOLCOTTVILLE IN 46795 311.84-xxxx LexID:2219059726 24. JEREMY K RUNKLE DOB: 1970 PO BOX 526 Dec 1990 Gender:Male Age:44 ANDERSON IN 46015.0526 311.84-xxxx LexID:2219059726 25. JEREMY K RUNKLE 008: 1970 ANDERSON UNIVERSITY APT Jan 1990 Gender:Male Age:44 ANDERSON IN 46012 311.84.xxxx LexID:2219059726 Records: 1 to 25 of 29 Result Page: 1 2 p Your DPPA Permissible Use: Use in the Normal Course of Business Your GLBA Permissible Use:Authorized by Consumer https://secure.accurint.com/app/bps/main 3/12/2014 Social Security Death Index (SSRI) Records - Social Security Death Index SSRI Records ... 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OR ZIP Code i OR Non-U.S. Location Social Security Number Details l� State SSN Issued !Any Social Security Number!,■- SSDI Search Tips Clear Form ( Begin Search ► Stay connected.Follow us( in the news I contact us I affiliates privacy policy I terms of use I site map I blog http://www.genealogybank.corn/gbnk/ssdi/?lname=&fname=&minit=&birthy_0=&birthy_... 3/12/2014 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Cumberland County Court of Common Pleas Number 12-7635 Civil Term ORDER AND NOW, this a day of , 2014, the Plaintiff is granted leave to serve the Notice of Sheriffs Sale of Real Property upon the Defendant, Jeremy Runkle a/k/a Jeremy M. Runkle, by regular mail and by certified mail, return receipt requested, to his last -known address of 204 Deanhurst Ave, Camp Hill, Pennsylvania 17011 and by posting the mortgaged premises of 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. /117tcL 14. (Zeic-•s6E127 `my) McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term c.) MOTION TO ADJOURN SHERIFF'S SALE Plaintiff, JPMorgan Chase Bank, National Association, by and through its attorneys, McCabe Weisberg and Conway, P.C., moves this Honorable Court for an Order adjourning the Sheriffs Sale scheduled for July 2, 2014 and avers as follows: I . Plaintiff filed a Writ of Execution, as well as the Affidavit required by Pa.R.C.P. 3129, in order to list the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 for Sheriffs Sale originally scheduled for March 12, 2014. 2. Plaintiff has postponed the Sheriffs Sale to the fullest extent permitted without requesting leave from the Court, and is now requesting that this Honorable Court allow the sale currently scheduled for July 2, 2014 to be postponed further until August 6, 2014 as service of the Notice of Sale is pending upon Defendant. 3. Plaintiff has complied with all the pertinent statutory and procedural rules of court governing the listing of real property for Sheriffs Sale. 4. Neither the parties hereto nor the parties previously set forth in the Affidavit Pursuant to Rule 3129 will be prejudiced by the adjournment of the Sheriff's Sale. 5. This case was previously assigned to the Honorable Kevin A. Hess, P.J. for consideration of Plaintiff's motion for alternative service. 6. The Defendant is unrepresented by counsel and the Plaintiff has no means to seek concurrence in the motion except by mail. WHEREFORE, Plaintiff prays that this Honorable Court grant an Order adjourning the Sheriffs Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 to the August 6, 2014 Sheriffs Sale with no additional advertising of said Sale and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C.P. 3129 being required, except for an announcement be made at the sale currently scheduled for July 2, 2014. MCCABE, 3/JEISBERG & C fr, P.C. BY: Ife] TERRENCE J. McCABE, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ ] LENA KRAVETS, ESQUIRE Attorneys for Plaintiff [ ] MARC S. WEISBERG, ESQUIRE [ ] MARGARET GAIRO, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] ANN E. SWARTZ, ESQUIRE [ ] JOSEPH I. FOLEY, ESQUIRE [ ] JENNIFER L. WUNDER, ESQUIRE [ ] CAROL A. DiPRINZIO, ESQUIRE Nathan olf, Es '— Wolf and Wol 10 West Hig Street Carlisle, P 013 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term MEMORANDUM OF LAW Plaintiff requested that the Sheriffs Sale originally scheduled for March 12, 2014 in this matter be continued for the legally allowable time without requesting the postponement from the Court. Plaintiff at this time requests that the Sheriffs Sale set for July 2, 2014 be adjourned to August 6, 2014 as service of the Notice of Sale is pending upon Defendant. Pursuant to Pa.R.C.P. 3129.3, the Court has the discretion to adjourn a Sheriff's Sale and dispense the requirement of new notice. WHEREFORE, Plaintiff prays that a special order of court be granted and the Sheriffs Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 be adjourned to the August 6, 2014 Sheriffs Sale with no additional advertising of said Sale and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C,P. 3129 being required, except that an announcement be made at the sate currently scheduled for. July 2, 2014. MCCABE, WE.ISBER, "vt CONAY, P.C. BY; '2`,`. je] TIR.RENCE J. MCCABE, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ) ANDREW L. MARK.OWITZ, ESQUIRE [ ) MARISA J, COHIEN, ESQUIRE ) ERIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. R.IG.A, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE ) LENA KRAVETS, ESQUIRE Attorneys for Plaintiff [ ] MARC S. WEIS.BE,RO, ESQUIRE [ j MARGARET GAIRO. ESQUIRE [ ] H.EIDI R.. SPIVAK, ESQUIRE [] CHRISTINE L. GRAHAM, ESQUIRE [ 1 ANN E. SWARTZ, ESQUIRE [ ] JOSEPH J..FOLEY, ESQUIRE [ ] JENNIFER. I.,. 'WUNDER, ESQUIRE [ ) CAROL A. DIPRINZIO, ESQUIRE Nathan olf, Esq. Wolf . d Wolf 10 West High Street Carlisle, PA 1.701.3 VERIFICATION The undersigned hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. MCCABE, WEISBERG & MAY, P.C. BY: , Vi l ERRENCE J. McCABE, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ ] LENA KRAVETS, ESQUIRE Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE MARGARET GAIRO, ESQUIRE HEIDI R. SPIVAK, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE ANN E. SWARTZ, ESQUIRE JOSEPH I. FOLEY, ESQUIRE JENNIFER L. WUNDER, ESQUIRE CAROL A. DiPRINZIO, ESQUIRE JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle Cumberland County; Number: 12-7635 Civil Term McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term CERTIFICATION OF SERVICE The undersigned attorney for Plaintiff, hereby certifies that I served a true and correct copy of the foregoing Motion To Postpone Sheriffs Sale, by United States Mail, first class, postage prepaid, on the 30th day of June, 2014, upon the following: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, PA, 17011 MCCAA&WgISBERG & CONWAY, tr. BY: 1(1 TERRENCE J. McCABE, ESQUIRE ] EDWARD D. CONWAY, ESQUIRE [ 1 ANDREW L. MARKOWITZ, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ ] LENA KRAVETS, ESQUIRE Attorneys for Plaintiff [ ] MARC S. WEISBERG, ESQUIRE [ ] MARGARET GAIRO, ESQUIRE [ 1 HEIDI R. SPIVAK, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] ANN E. SWARTZ, ESQUIRE [ ] JOSEPH I. FOLEY, ESQUIRE [ ] JENNIFER L. WUNDER, ESQUIRE [ ] CAROL A. DiPRINZIO, ESQUIRE JULE- 1):1 r). FF CU l lLEJ'\LA U PENNSYLVANIA JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term ORDER Q AND NOW, this / day of , 2014, upon consideration of Plaintiffs Motion to Adjourn the Sheriff's Sale curren ly scheduled in the above -captioned matter for July 2, 2014, it is hereby ORDERED that the Sheriff's Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 is adjourned to the August 6, 2014 Sheriffs Sale. It is FURTHER ORDERED that no additional advertising of said Sale is necessary and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C.P. 3129 is required. The postponement shall be announced at the July 2, 2014 Sheriffs Sale. Distribution: BY THE COURT: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, PA, 17011 Cabe, Weisberg & Conway P.C. 123 South Broad Street, Suite 1400 Philadelphia, PA 19109 Office of the Sheriff —• pl. iEct_. Commonwealth of Pennsylvania In the Court of Common Pleas of Cumberland County AFFIDAVIT OF SERVICE JPMorgan Chase Bank, National Association vs. Jeremy Runkle a/k/a Jeremy M. Runkle Commonwealth of Pennsylvania County of Dauphin ss. 11 CASE NO.: 12-7635 I, Robert Calantropio, a competent adult, being duly sworn according to law, depose and say that at 1:09 PM on 06/25/2014, I served Jeremy Runkle a/k/a Jeremy M. Runkle at 204 Deanhurst Avenue, Camp Hill, PA 17011 in the manner described below: ❑ Defendant(s) personally served. c-, ria c E Adult family member with whom said Defendant(s) reside(s). ` co c ❑ -*--.--, Relationship is yr*� = `r� ❑ Adult in charge of Defendant(s) residence who refused to give name and/or relationsha > .-.3 C= r- = CD ❑ Manager/Clerk of place of lodging in which Defendant(s) reside(s). y<CD '� © off; ❑ Agent or person in charge of Defendant's office or usual place of business. y c - .' an officer of said Defendant's company. Other: The documents were posted to the premises, a true and correct copy of Order; Notice of Sheriff's Sale of Real Property issue x Sworn too and subscribed before me on this Robert Calantropio d$� day of T4frtr , 20L. AOSS n the above captioned matter. NOTARY PUIC ONWEAL7F1 OF PENNSYLVANIA Notarial Seal John F. Shinkowsky, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Sept. 28, 2014 Member. Pennsylvania Msociation of Notaries 1 Huntington Quadrangle, Suite 2SO4 Melville, NY 11747 (516) 284-5850 Atty File#: 232813 - Our File# 32726 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term MOTION TO ADJOURN SHERIFF'S SALE Plaintiff, JPMorgan Chase Bank, National Association, by and through its attorneys, McCabe Weisberg and Conway, P.C., moves this Honorable Court for an Order adjourning the Sheriffs Sale scheduled for August 6, 2014 and avers as follows: 1. Plaintiff filed a Writ of Execution, as well as the Affidavit required by Pa.R.C.P. 3129, in order to list the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 for Sheriffs Sale originally scheduled for March 12, 2014. 2. Plaintiff has postponed the Sheriffs Sale to the fullest extent permitted without requesting leave from the Court, and is now requesting that this Honorable Court allow the sale currently scheduled for August 6, 2014 to be postponed further until October 1, 2014 as Plaintiff is reassessing damages. 3. Plaintiff has complied with all the pertinent statutory and procedural rules of court governing the listing of real property for Sheriffs Sale. 4. Neither the parties hereto nor the parties previously set forth in the Affidavit Pursuant to Rule 3129 will be prejudiced by the adjournment of the Sheriffs Sale. S. This case was previously assigned to the Honorable Kevin A. Hess, P.J. for consideration of Plaintiffs motion for alternative service. 6. The Defendant is unrepresented by counsel and the Plaintiff has no means to seek concurrence in the motion except by mail. WHEREFORE, Plaintiff prays that this Honorable Court grant an Order adjourning the Sheriffs Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 to the October 1, 2014 Sheriffs Sale with no additional advertising of said Sale and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C.P. 3129 being required, except for an announcement be made at the sale currently scheduled for August 6, 2014. MCCABE, WEISBERG & CONWAY, P.C. BY: [ ] TERRENCE J. McCABE, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ [ ] MARISA J. COHEN, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ [ ] LENA KRAVETS, ESQUIRE Attorneys for Plaintiff ] MARC S. WEISBERG, ESQUIRE ] MARGARET GAIRO, ESQUIRE ] HEIDI R. SPIVAK, ESQUIRE ] CHRISTINE L. GRAHAM, ESQUIRE ] ANN E. SWARTZ, ESQUIRE ] JOSEPH I. FOLEY, ESQUIRE ] JENNIFER L. WUNDER, ESQUIRE ] CAROL A. DiPRINZIO, ESQUIRE Natha Wo 10 West Street Carlisle, PA 17013 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. MeCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID 4 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA .1. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term MEMORANDUM OF LAW Plaintiff requested that the Sheriffs Sale originally scheduled for March 12, 2014 in this matter be continued for the legally allowable time without requesting the postponement from the Court. Plaintiff at this time requests that the Sheriffs Sale set for August 6, 2014 be adjourned to October I, 2014 as Plaintiff is reassessing damages. Pursuant to Pa.R.C.P. 3129.3, the Court has the discretion to adjourn a Sheriffs Sale and dispense the requirement of new notice. WHEREFORE, Plaintiff prays that a special order of court be granted and the Sheriffs Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 be adjourned to the October 1, 2014 Sheriffs Sale with no additional advertising of said Sale and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C.P. 3129 being required, except that an announcement be made at the sale currently scheduled for August 6, 2014. MCC WEISBI & CONWAY, P.C. BY: Lai(./ TERREN J. McCABE, ESQUIRE EDW . CONWAY, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE MARISA J. COHEN, ESQUIRE BRIAN T. LAMANNA, ESQUIRE JOSEPH F. RIGA, ESQUIRE CELINE P. DERKRIKORIAN, ESQUIRE LENA KRAVETS, ESQUIRE Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE GARET GAIRO, ESQUIRE HEIDI R SPIVAK, ESQUIRE CHRISTL GRAHAM ANN E. SWARTZ, ESQUIRE QUIRE JOSEPH I. FOLEY, ESQUIRE JENNIFER L. WUNDER, ESQUIRE ( 1 CAROL A. DiPRINZIO, ESQUIRE athan Wo Wolf and 10 West Carlisle, sq igh'treet A 17013 VERIFICATION The undersigned hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of l8 PA.C.S. §4904 relating to unsworn falsification to authorities. MCCAB�E,�WEIISBERG & CONWAY, P.C. BY: [ ] TERREN€E J. McCABE, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ ] LENA KRAVETS, ESQUIRE Attorneys for Plaintiff [ ] MARC S. WEISBERG, ESQUIRE [--1 MARGARET GAIRO, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] ANN E. SWARTZ, ESQUIRE [ ] JOSEPH I. FOLEY, ESQUIRE [ ] JENNIFER L. WUNDER, ESQUIRE [ ] CAROL A. DiPRINZIO, ESQUIRE JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle Cumberland County; Number 12-7635 Civil Term McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH L FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term CERTIFICATION OF SERVICE The undersigned attorney for Plaintiff, hereby certifies that I served a true and correct copy of the foregoing Motion To Postpone Sheriffs Sale, by United States Mail, first class, postage prepaid, on the 5th day of August, 2014, upon the following: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, PA, 17011 MCCABE, WEISBERG & CONWAY, P.C. BY: [ ] TERRENCE J. McCABE, ESQUIRE C S. WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] .MARISA J. COHEN, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] ANN E. SWARTZ, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] JOSEPH 1. FOLEY, ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE [ ] JENNIFER L. WUNDER, ESQUIRE [ ] LENA KRAVETS, ESQUIRE [ ] CAROL A. DiPRINZIO, ESQUIRE Attorneys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant THEF;LE0-OFFICE' HPROTHONO TARY 2014 AUG -5 PM 3: 4 I CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 12-7635 Civil Term ORDER AND NOW, this r day of t/ , 2014, upon consideration of Plaintiffs Motion to Adjourn the Sheriffs Sale currently scheduled in the above -captioned matter for August 6, 2014, it is hereby ORDERED that the Sheriffs Sale of the property known as 204 Deanhurst Avenue, Camp Hill, PA 17011 is adjourned to the October 1, 2014 Sheriff's Sale. It is FURTHER ORDERED that no additional advertising of said Sale is necessary and no new notice to the parties previously set forth in the Affidavit Pursuant to Pa.R.C.P. 3129 is required. The postponement shall be announced at the August 6, 2014 Sheriffs Sale. Distribution: ✓ Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, PA, 17011 cCabe, Weisberg & Conway P.C. 123 South Broad Street, Suite 1400 Philadelphia, PA 19109 Office of the Sheriff a EA' fiat S//y- BY THE COURT: jr..., 4 / McCABE, WEISBERG & CONWAY, P.C. BY: Brian T. LaManna, Esquire Attorney Identification Number 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 Telephone: (215) 790-1010 Email: blamanna@mwc-law.com Attorneys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff, v. Jeremy Runkle a/k/a Jeremy M. Runkle, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA m W ax• @ NO. 12-7635 Civil Term xrn c PLAINTIFF'S MOTION TO REASSESS DAMAGES NOW COMES the Plaintiff, JPMorgan Chase Bank, National Association (hereinafter "Plaintiff') by and through its attorneys, McCabe Weisberg & Conway, P.C., and hereby files this Motion to Reassess Damages, to direct the Prothonotary to amend the judgment in this matter, and order the Sheriff to amend the Writ nunc pro tunc, and in support thereof, Plaintiff avers the following: 1. Plaintiff is the current holder of the Note at issue, which is attached hereto as Exhibit A, and the current assignee of the Mortgage at issue pursuant to the Assignment recorded in the Office of the Recorder of Deeds for Cumberland County as Instrument Number 201035739 and attached hereto as Exhibit B. 2. Plaintiff commenced this foreclosure action by filing a Complaint in mortgage foreclosure on December 20, 2012 (hereinafter "the Complaint"). A true and correct copy of the 1 Complaint without exhibits is attached hereto as Exhibit C. 3. When no Answer or Response to the Complaint was filed, Judgment by default was entered on April 1, 2013, in the amount of $120,659.78. A true and correct copy of the Praecipe for Judgment is attached hereto as Exhibit D. 4. The judgment has not been satisfied. 5. A Sheriff's sale of the property known as and located at 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011 (hereinafter "the Property"), is currently scheduled for October 1, 2014. 6. Pursuant to Pa.R.C.P. 1147(6), a complaint in mortgage foreclosure must set forth a demand for judgment for the amount due. 7. The judgment amount Plaintiff specified in the Complaint in compliance with Pa.R.C.P. 1147(6), is currently insufficient to satisfy the actual amounts due pursuant to the Mortgage and Note. 8. According to the terms and conditions of the Mortgage and Pennsylvania law, Plaintiff is able to recoup costs, fees and other expenses stemming from the default of Defendant Jeremy Runkle a/k/a Jeremy M. Runkle (hereinafter "Defendant") and the resulting foreclosure action. A true and correct copy of the Mortgage is attached hereto as Exhibit E. 9. Specifically, Plaintiff is entitled to recover funds paid on Defendant's behalf for escrow advances and corporate advances, which may include inter alia, property inspections, and property preservation fees. Please see attached Exhibit A and Exhibit E, respectively. 10. The Note and Mortgage further provide that Plaintiff is entitled to additional interest incurred after judgment, at the rate entered on the Note. Please see attached Exhibit A and Exhibit E, respectively. 2 11. Pursuant to the terms and conditions of the Mortgage and Pennsylvania law, Plaintiff is entitled to recoup the attorney fees and costs incurred in pursuing a judicial remedy upon default. 12. Since filing the Default Judgment, Plaintiff has expended or incurred additional sums on behalf of Defendant and after appropriate reassessment, the correct amount of damages should be reflected as follows: Principal Balance Interest through 08/06/14 Escrow Advance Recoverable Balance Property Preservation Property Inspections Attorney Fees Attorney Costs Late Charges Suspense Balance REASSESSED TOTAL $ 101,444.05 $ 22,512.88 $ 11,369.83 $ 6,262.49 $ 188.77 $ 243.00 $ 3,545.00 $ 4,292.75 $ 113.34 $ -52.00 $ 149,920.11 13. Plaintiff's foreclosure judgment is strictly in rem, to effectuate a Sheriff's sale of the Property and does not impute any personal liability to Defendant. WHEREFORE, Plaintiff respectfully requests that this Court order that the judgment be amended as set forth above, order the Sheriff to amend the Writ nunc pro tunc as set forth above and for any other such relief as the Court deems necessary. 6' 6(/ Date 1 Respectful miffed, nna, Esquire cCab/ eisberg & Conway, P.C. Atto ys for Plaintiff 3 EXHIBIT "A" r: NC' Ai NOTE 148123 September 25 , 2002 CAMP HILL , PENNSYLVANIA [Date] [City] [State) 204 DEANHURST AVENUE CAMP HILL, PA 17011 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that 1 have received, I promise to pay U.S. $ 118,000.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is GATEWAY FUNDING DIVERSIFIEDMORTGAGE SERVICES, L.P. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder". 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.625 The interest rate required by this Section 2 is the rate I will pay both before and after any default des- cribed in Section 6(B) of this Note. .3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on November , 2002 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly pay- ment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on October 1 , 2032 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 500 OFFICE CENTER DRIVE, SUITE 325 FORT WASHINGTON, PA 19034 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 7.57 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Princi- pal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not make all the monthly pay- ments due under the Note. 1 may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. How- ever, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If 1 make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit: and (b) any sums already collected from me which exceeded permitted limits MULTISTATE FIXED RATE NOTE --Single Family --Fannie Mae/Freddie Mac UNIFORM INSTRUMENT 3200-1.frm 10/00 mis Form 3200 1/01 (page 1 of 3 pages) 148123 will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. 1 will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, 1 will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will stip have the right to do so if 1 am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obli- gated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the pro- tections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses MULTISTATE FIXED RATE NOTE -Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 3200 1/01 (page 2 of 3 pages) 3200-2.frm 10/00 mis r b- a 148123 which might result if I do not keep the promises which I make in this Note. That Security Instrument des- cribes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or tranferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or trans- ferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be ex- ercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED JEREM (Seal) RUN LE -Borrower (Seal) -Borrower (Seal) Pay to the order of -Borrower without recourse Gateway - ding Diversified Mortgage Servic , L. By it-Gener•IP 1 Ant Vi F. Bru o resident MULTISTATE FIXED RATE NOTE --Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 32001/01 (page 3 of 3 pages) 3200-3.frm 10/00 mis (Seal) -Borrower [Sign Original Only] F,XHIBIT "B" Prepared By and Return To: Referral Department GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 NMI GMM File Number: 104506FC Parcel ID#: 01-22-0533-050 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. (Assignor), for and in consideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER. JPMORGAN CHASE BANK, N.A., AS ACQUJRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed JEREMY RUNKLE, Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. Bearing date of: September 25, 2002; Amount Secured: $118,000.00; Recorded on October 02, 2002; in Book 1775 Page 2581; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 204 Deanhurst Avenue, Camp Hill, PA 17011 AS FURTHER DESCRIBED 1N EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, ha eAecuted and sealed with its corporate seal this Assignment of Mortgage on this J.2 day of 110/9 , 2010. (Affix Corporate Seal) ss: STATE OF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. Alit IfG2j&/el (SEAL) Name:No =.Nadarevic Title J,.: President ,/' / 1/ ame: Gwendolyn Austin Title: vice president Fonda ) COUNTY OF DINof ) (SEAL) BE IT REMEMBERED, that on this , 13- day of l'63 \I ' , 2010, before me, the subscriber, a Notary Public personally appeared Nura Nadarevlc Vice President Gwendolyn Austin Vice President MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. AS NOMINEE FOR GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary . ct and deed of such corporation made by virtue of a Resolution of its Board of Directors. I hereby certify the address of the Assignee is: 7255 Baymeadows Way, Jacksonville, FL 32256 44:i- r IL ILI Case #: 104506FC Notary,49„ ,,,ter M commissron e''— itany Public";;SFataY0! F r) a v!y'Cgtmti. CxPW s RA NUL Commission aT;+p' 2G3j Rnr1Yri 7h- _. .#'OL*'.$5145;? FIRST AMERICAN TITLE INSURANCE CO. Commitment Number. RUNK242-02R SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment Is described as follows: ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern fine of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty (40) feet to point on the southern line of Lot No. 265: thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths (137.97) feet to a point In the west side of Deanhurst Avenue; thence sauthwardly along the western side of Deanhurst Avenue on hundred (100) feet to a point, the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office In Plan Book 2. Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35. See also Plan recorded on July 10, 11356 in Plan book 8, Page. 1 Certify this to be recorded In Cumberland County PA Recorder of Deeds ALTA Commitment (RUNK242.02R.PFDiRLNK242-02R14) Schedule C BI(17751"62595 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201035739 Recorded On 12/6/2010 At 9:48:44 AM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 77996 User ID - KW * Mortgagor - RUNKLE, JEREMY M * Mortgagee - JPMORGAN CHASE BANK N A * Customer - GOLDBECK MCCAFFERTY & MCKEEVER *FEES * Total Pages - 4 STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES - RECORDER OF DEEDS PARCEL CERTIFICATION FEES COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $23.50 $11.50 $10.00 $2.00 $3.00 $50.50 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA • j,&RECORDECots * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. ° 111111111i III EXHIBIT "C" Supreme. Court, of Plennsylvania. Cou:,a Co PIeas let AM DettIkIICI County For Prorho,rotao' Use only: j� l Docket No. is ' 7(35 01%0 Te 1Q The it f0r•rnation collected on This fbrin is used solely for count administration purposes. This form does noi sirlipleiiiertl or rej7k ci' the' n and service plcadim s:or other jnij)c is as 1•edWrcd by law 01 rules of. court. Co ntnencement of Action: 0 Complaint 0 Writ of Summons 0 Petition ❑ Transfer from Another Jurisdiction 0 Declaration of Taking ' Lead .Plaintiffs Name:.IPMorgan Chase Rank, National Association Lead Defendant's Name: Jeremy Runkle a/k/a Jeremy M, Runkle Are there money damages requested? 0 Yes E3 No Dollar Amount Requested: 0 within arbitration limits (check one) 0 outside arbitration limits Is this a Class Action Suit? 0 Yes El No Is this an MD.I Appeal? 0 Yes E3 No Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg and Conway, P.C. 1• 0 Check here if you have no attorney (a Self -Represented ]Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance CONTRACT (do not include Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card 0 Debt Collection: Other CIVIL APPEALS Administrative Agencies 0 Board of Assessment ' 0 Board of Elections 0 Department of Transportation ❑ Premises Liability (does not include 0 Statutory Appeal: Other mass tort) ❑ Slander/Libel/ Defamation 0 Employment Dispute: O Other: Discrimination ❑ Employment Dispute: Other ❑ Zoning Board 0 Other MASS TORT • ❑ Other ❑ Asbestos ❑ Tobacco ' ❑ Toxic Tort - DES ❑ Toxic Tort -Implant ❑ Toxic Waste ❑ Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation MISCELLANEOUS 0 Common Law/Statutory Arbitration 0 Declaratory Judgment 0 Mandamus ❑ Ground Rent 0 Non Relations 0 Landlord/Tenant Disput -Domestic Order I PROFESSIONAL LIABILITY ❑ Dental ❑ Legal Mortgage Foreclosure: Residential , ❑Mortgage Foreclosure: C 0 Partition r i Quiet Title ❑ Other: Restraining ❑uo Warrantoommercial Q 0 Replevin 0 Other: ❑ Medical { ❑ Other Professional: Updated 1/1/2011 FORM 1 JPMorgan Chase Bank, National Association Plaintiff vs. Jeremy Runkle a/k/a Jeiemy M. Runkle Defendant IN THE COURT OF COMMON PLEAScpy CUMI3ERLAND COUNTY, PENNSYLVANIA ....., ----uri (-.1 ...-....) C) t-- -"ni •-<-' ,..) /01 ' 71035 Civil r— ..> CI ....ft. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court -supervised conciliation conference in an effort to resolve this matter with your lender. Ryon 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 appointinent 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 legalrepresentative complete a fmancial 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. 1(117/ Date Respectfully subm. :ted: e of Counsel for P MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDM R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank, National Association 10790 Rancho Bernardo Road San Diego , California 92127 v. Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania 17011 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number /rA - 735" COMPLAINT IN MORTGAGE FORECLOSURE 1 Tem File 58926 Page 1 NOTICE You have been sued in court. if you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice tir.setycci, by entering a written appearance ;personally or by attorney and :filing in writing with the court -your defenses or objections to the 'Clainis'set forth againstyou: You -arc wailled that ifyou fail to do so the, ease. may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WEIH 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere dcfenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia e..serita o en persona 0 con im abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en Contra do su persona. Sea avisado que si usted no se defiende, la corte tomaramedidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Mews, la, cote puede decidir a favor del demandants y requiere. que usted cumpla con todas las' prpvisiones de esta dcmanda. listed puede perder dinero o sus propiedades. u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDI ATAMENTE. SI USTED NO HENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA MONA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NTNGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 File # 58926 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Unless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgtnent that we obtain. Upon your written request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle Cumberland County Tiie #I 58926 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMorgan Chase Bank, National Association, duly organized and doing business at the above -captioned address. 2. The Defendant is Jeremy Runkle a/k/a Jeremy M. Runkle, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last -known address is 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011, 3. On September 25, 2002, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems Inc., as nominee for Gateway Funding Diversified Mortgage Services, L.P. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1775, Page 2581, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 4. On November 12, 2010, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems Inc., as nominee for Gateway Funding Diversified Mortgage Services, L.P. to JPMorgan Chase Bank, N.A., as Acquirer of Certain Assets and Liabilities of' Washington Mutual Bank from the Federal Deposit Insurance Corporation Acting as Receiver, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assigninent of Mortgage Book Instrument No. 201035739, such Assignment ofMortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due May 1, 2011 and each month thereafter are due and unpaid, and by the terns of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File 6 58926 Page 4 7. The following amounts are due on the mortga(Ye:. Principal Balance $ 101,444.05 Interest from April 1,2011 through November 30, 2012 $ 11,201.20 Late Charges $ fl334 Attorney's Fee $ 1,650.00 Escrow Advance $ 5,819.42 Property Preservation $ 188.77 Property Inspections $ 243.00 GRAND TOTAL $ 120,659.78 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff s sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested required. 9. A copy of Chase's Homeowner Information Packet is attached hereto as Exhibit "B. " WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $120,659.78, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. MCCABE, WEISBERG AND COP+TWAY,P.C. BY' [ "NCE J. McCAB,...?;, ESQUI [1IARC S. WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] MARGARET G.AIRO, ESQUIRE 1 1 ANDREW L. MARKOWITZ, ESQUIRE I 1 HEIDI R. SPIVAK, ESQUIRE 1 ] MARISA J. COHEN, ESQUIRE ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L, GRA.H.AM, ESQUIRE [ J.BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff File 458926 Page 5 VERIFICATION .hereby states thatslie is ),S of JPMorgan Chase Bank, National Association, Plaintiff in this matter, that she is authorizedto make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are.true and correct to the best of ter 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: /A 6" (917 /-4-- 43/ Name: <- Title: 1/166- (4/c7?EJ7 1 Name: JPMorgan Chase Bank, National Association v. Jeremy Runkle a/k/a Jeremy M. Runkle File # 58926 Page 6 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania 17011 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy -M. -Runkle. Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-7635 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUD ENT has been entered in the above roceeding iduitsoe as indicated below. Prot X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession lf you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I, FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff' v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-7635 Civil Term (-) Fri W rn 1) r.) 717. :1:43 2. ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant, Jeremy Runkle a/k/a Jeremy M. Runkle, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal Interest from 12/01/12 to 03/22/13 Total $ 120,659.78 N/A $ 120,659.78 McCABE, E BERG AND CONWAY, P.C. BY: [ Terrence J. vlcCabe, Esq. [ 1 Edward D. onway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. Attorneys for Plaintiff AND NOW, this r+ day of [ ] Marc S. Weisberg, Esq. .[-erMargaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. , 2013, Judgment is entered in favor of Plaintiff, JPMorgan Chase Bank, National Association, and against Defendant, Jeremy Runkle a/k/a Jeremy M, Runkle, in rem only and not in personam, and damages are assessed in the amount of $120,659.78, plus interest and costs. McCABE, WEISBERG AND CONWAY, P.C. BY: TERR.ENCE J. McCABE, ESQUIRE - ID 16496 MARC S. WEISBERG, ESQUIRE - ID 4 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID 4 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID 474770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID 4 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID 4 309480 BRIAN T. LAMANNA, ESQUIRE - ID 4 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID 4 57716 JOSEPH I. FOLEY, ESQUIRE - ID 4314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-7635 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law, deposes and says that the Defendant, Jeremy Runkle a/k/a Jeremy M. Runkle, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendant, Jeremy Runkle a/k/a Jeremy M. Runkle, is over eighteen (I 8) years of age, and resides as follows: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue ' Camp Hill, Pennsylvania 17011 SWORN AND SUBSCRIBE BEFORE ME THI 4wisw /A .a.�ri . A NOTARY PUB, k,. 'NOTARIAL aEAL :Barbara .!- Moyer- NotaryPublic ( City al Philail�p0i, Pb Casty, MY M -- -. IAlW:12, 1914 SS. McCABE, WE G AND CONWAY, P.C. BY: [ ] Terrence . McCabe, Esq. [ ] Edward ti . Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph 1. Foley, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [_-Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: RUNKLE First Name: JEREMY Middle Name: M. Active Duty Status As Of: Mar -22-2013 Results as of : Mar -22.2013 07:00:54 SCRA 3.0 ::: ..1':::..--;efi:49'.4i01)*Vtt.....0tPaYRPf.!,cAYP.P.14.P.P191.;),0,1c,.4*,41.104....,,:•;*, AsIve Du'yStarl Oslo:.:,.,...'-i,i,,,I:,..' ,;:,:4t,?,:,:444, 4,2)6; i;.4.0;A,, liZOnfegOl'igi4VMMt-'-i' ':1'.::',sr.'-'C''3;.':'::.s.ei4:64g^W'' NA NA "144:11iT. .,•:. Br,.144h6„tt',„ NA Thls response reflept(4.1ptitdgIVecflye d1.40siet4 based Onta,A1145$4,e, Status Date ::: ..1':::..--;efi:49'.4i01)*Vtt.....0tPaYRPf.!,cAYP.P.14.P.P191.;),0,1c,.4*,41.104....,,:•;*, !0tiv,p4.;ii44":4•4'.0.449,..i.::::::.;g:%a:;1.,,:,,A,;1. .-'--..'',..,..-..,..:10:,„f',..,',.•:.4,,:.,,,-.1,,..V, Active oety•Stail Date. : „ •:' : : ,:.:' .1..:..::',';:::,,.',AOi4Dijeiniigiiikt.lv,i,; maignAft gVe :.:j.t.....L.. .cii*i,'"..'0)..-'-'p4.i.W.:,,:-'„9,5 NA4,;;:',;::',-:',,,i'.: NA f!"IA '.-4...;..-...•.•''.-.Z.,A....,4 si c Na 4Tit * NA This re punas reflects 4;44 Indiduai left ae-tiViit.iY'4101‘tigf0si:41ays proced4 thc4;:b1.1ty Status Date okatf.1.‘ K'$if tttiff# -•.:‘,<::-?-.,i..-j,,i,-•?;i.-i-,.:ei4,,i,-0,,siii.o:'i,,,:giiio::i4gi;',11i.:AAkkiil,i,ii•xitil'iViZ,";4',e4i.40kik;i,..4.4j, !0tiv,p4.;ii44":4•4'.0.449,..i.::::::.;g:%a:;1.,,:,,A,;1. ar4iti.:r.Qii44i*:;.4 '6ii'i-',:;:'::':-.11;1.i:',::" SViNiO'i;44gii'fig(4,:a4VIVE.Igt E.Rggkmggmtnri,rn',',:z,2.:;':,',',''.i'or;44,-:6'4'.i,'ii'',ijj.::::!';',t':.,:,:',:, NA \•41-kNi:::k.;...,•.. (,..,7i.;,.,-:-..,4*72,1 NA This response reflects whether4441:44111s/hel:unitner4,7el,rottearly report for active duty Upon searching the data banks of the Department of Defense Manpowe't Data Canter;.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. 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 the enforcement of the Servicemembers Civil Relief Act (50 USG App. § 501 et 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.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. 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(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All 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 aro 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: Y29DN9A3E0A13E0 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID 416496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID 4 28009 HEIDI R. SPI VAX, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID 4 87830 KEVIN T. MCQUAIL, ESQUIRE - ID 4 307169 CHRISTINE L. GRAFIAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-7635 Civil Term AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last -known mailing address of the Defendant is: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania 17011 SWORN AND SUBSCRIBED DAY NOTAR NCITAR IAL. k Barbara J. Moyer- Notary Pubflr, City of Philatislptia, nilaift/p114 Court), C9MMliSI0N W1Rp JAPE 12,20.14. SS. McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Te e ce J McCabe, Esq. [ J Edward 1. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ 1 Joseph I. Foley, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [--rMargaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. MCCABE, WEISBERG AND CONWAY, P.C. 13Y: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E, SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 JPMorgan Chase Bank, National Association Plaintiff v. Jeremy Runkle a/k/a Jeremy M. Runkle Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-7635 Civil Term CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THI DAY OF 3 City of Phil&ti bi , {,ti., .., ( •s'i711'ft. 6:J G.�lI.0 jL�i ut ,. • MYOOMMISSfONE ai.-ESJAN:12,201,: McCABE, WEISB1i RG AND CONWAY, P.C. BY: [ ] Terrence J McCabe, Esq. [ ] Edward Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L, Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [„--rMargaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terre 'ce J. M abe, Esq. [ ] Edward D. C. way, Esq. [ ] Andrew L. Markowitz, Esq. [ ]Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. Attorneys for Plaintiff Marc S. Weisberg, Esq. Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. EXHIBIT sa• 3”5 4 Tt, After Recording Return To: GATEWAY FUNDING • 500 OFFICE CENTER DRIVE, SUITE 325 FORT WASHINGTON, PA 19034 ATTN: Final Document Department Prepared by TINA FRE1DHOF 148123 #?OSERT P. ZIEGLER 1.EOORDER OF DEEDS '''.BERLAHD 001AITY-P;, fIz OCT 2 fin 8 45 [Space Above This Line For Recording Data] MORTGAGE MIN: 100070200001481232 DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sec- tions 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16, (A) "Security Instrument" means this document, which is dated September 25 . 2002 together with all Riders to this document. (B) "Borrower" is JEREMY RUNKLE Borrower is the mortgagor under this Security Instrument. (C) "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate corporation that is act- ing solely as a nominee for Lender and Lender's successors and assigns. MERS is the mortgagee under this Security Instrument. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of P. O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. (D) "Lender" Is GATEWAY FUNDING DIVERSIFIEDMORTGAGE SERVICES, L.P. Lender is a LIMITED PARTNERSHIP organized and existing under the laws of THE COMMONWEALTH OF PENNSYLVANIA Lender's address is 500 OFFICE CENTER DRIVE, SUITE 325 FORT WASHINGTON, PA 19034 (E) "Note" means the promissory note signed by Borrower and dated The Note states that Borrower owes LenderOne Hundred Eighteen Thousand and no/100 Dollars (U.S. $ 118,000.00 ) plus interest. Borrower has promised to pay this debt In regular Periodic Payments and to pay the debt in full not later than October 1 , 2032 (F) "Property" means the property that is described below under the heading "Transfer of Rights in the Property." (G) "Loan" means the debt evidenced by the Note, plus Interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (H) "Riders" means all riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: ❑ Adjustable Rate Rider ❑ Balloon Rider ❑ 1-4 Family Rider ❑ Condominium Rider ❑ Planned Unit Development Rider ❑ Biweekly Payment Rider 0 Second Home Rider 0 Other(s) [specify]: (I) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordi- nances and administrative rules and orders (that have the effect of law) as well as all applicable final, non -appealable judicial opinions. PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 (page 1 of 14 pages) M3039-1.frm (MERS) 10/00 mis Bi(1 775PG2581 EXHIBIT A 148123 • •(J) ''Community Asso9iation Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (K) "Electronic Funds Transfer" means any transfer of funds,other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine trans- actions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (L) "Escrow Items" means those items that are described in Section 3. (M) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (N) "Mortgage insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. (0) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. (P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that govems the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (Q) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and con- vey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS the following described property located in the County of CUMBERLAND which currently has the address of 204 DEANHURST AVENUE CAMP HILL [City] [Street] , Pennsylvania 17011 ("Property Address"): [Zip Code] PENNSYLVANIA --Single Family --Fannie Mae/Freddle Mao UNIFORM INSTRUMENT Form 3039 1/01 (page 2 of 14 pages) M3039-2.frm (MERS) 10/00 mis BK 17751362582 • 148123 TOGETHER WITH all the improvements now or hereafter erected on the property, and all ease- ments, appurtenances, and fixtures now or hereafter a part of the property. All replacements and addi- tions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property". Borrower understands and agrees that MERS holds only legal title to the in- terests granted by Borrower in this Security Instrument, but, if necessary to comply with law or custom, MERS (as nominee for Lender and Lender's successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing and canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U. S. currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as select- ed by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are in- sufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or retum them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied In the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. PENNSYLVANIA --Single Family --Fannie Mae/Freddle Mao UNIFORM INSTRUMENT Form 30391/01 (page 3 of 14 pages) M3039-3.frm (MERS) 10/00 mis BK 1 775FG2583 148123 ti , If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment re- ceived from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepay- ments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due un- der the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note Is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insur- ance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments,if any,be escrowed by Borrower,and such dues,fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obliga- tion to pay the Funds for any or all Escrow Items.Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and,if Lender requires,shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" Is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Appli- able Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instru- mentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. PENNSYLVANIA --Single Famlry--Fannle Mae/Freddle Mao UNIFORM INSTRUMENT Form 3039 1/01 (page 4 of 14 pages) 3039-4.frm 10/00 mis Bili 775PG2584 148123 If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA,but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property,if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items,Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner accept- able to Lender, but only so long as Borrower is performing such agreement; (b) contests the Hen in good faith by,or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceed- ings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordi- nating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identify- ing the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or re- porting service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insur- ance. This Insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and certification services and.subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the re- view of any flood zone determination resulting from an objection by Borrower. If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 3039 1/01 (page 6 of 14 pages) 3039-5.frm 10/00 mis BK1775PG2585 148123 All insurance policies required by Lender and renewals of such policies shall be subject to Lend- er's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional Toss payee.Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall Include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. In the event of Ioss,Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrow- er any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may tile, negotiate and settle any available insurance claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30 -day period will begin when the notice is given. In either event, or if Lender acquires the Property under Sec- tion 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of uneamed premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy,unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating cir- cumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Proper- ty. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. if insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of such repair or restora- tion. PENNSYLVANIA••SIngle FamtlyFannle Mae/Freddie Mao UNIFORM INSTRUMENT Form 30391/01 (page 6 of 14 pages) 3039-6.frm 10/00 mis ►B10,775PG2586 148123 Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. 8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application proc- ess, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations conceming Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Property and Rights under this Security instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfei- ture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever Is reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Agree- ment, including protecting and/or assessing the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorney's fees to protect its interest in the Property and/or rights under this Security instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Al- though Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. if Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain. the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to ob- tain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substan- tially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such Toss reserve shall be non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender PENNSYLVANIA --Single Family --Fannie Mae/Freddle Mac UNIFORM INSTRUMENT Form 3039 1/01 (page 7 of 14 pages) 3039-7.frm 10/00 mis 6K1775PG2587 148123 • requires separately designated payments toward the premiums for Mortgage Insurance. If Lender re- quired Mortgage Insurance as a condition of making the Loan and Borrower was required to make sepa- rately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the pre- miums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement be- tween Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain fosses it may incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage In- surance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk,or reduce losses. These agree- ments are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insurer may have available (which may include funds obtain- ed from Mortgage Insurance premiums). As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsur- er, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the pre- miums paid to the insurer, the arrangement is often termed "captive reinsurance." Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund. (b) Any such agreements will not affect the rights Borrower has - if any - with respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mort- gage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a re- fund of any Mortgage insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. if the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period,Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is com- pleted. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security In- strument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Pro- ceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Pro- ceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 3039 1/01 (page 8 of 14 pages) 3039-8.frm 10/00 mis BK1775PG2588 • 148123 In the event of a partial taking, destruction, or Toss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multi- plied by the following fraction: (a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately be- fore the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss In value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if,after notice by Lender to Borrower that the Oppos- ing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrow- er fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in re- gard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgement, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgement, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceed- ings against any Successor in interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy Including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"); (a) is co- signing this Security Instrument only to mortgage, grant and convey the co-signer's interest in the Prop- erty under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, mod- ify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent. PENNSYLVANIA --Single Famlly--Fannie Mae/Freddle Mac UNIFORM INSTRUMENT Form 3059 1/01 (page 9 of 14 pages) 3039.9.frm 10/00 mis BK.! .7'7 ,5 PG 2 5 8 9 148123 Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Bor- rower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shalt not be released from Bor- rower's obligations and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Sec- tion 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security instrument to charge a spe- cific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded per- mitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the prin- cipal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepay- ment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address un- less Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only one designated notice address under this Security instrument at any one time. Any notice to Lender shall be given by delivering it or by mailing it by first class mall to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security instrument shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security Instrument. 16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be gov- emed by federal law and the law of the jurisdiction in which the Property is located. All rights and obliga- tions contained in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. in the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to to take any action. 17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument. PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 30391/01 (page 10 of 14 pages) 3039.10.frm 10/00 mis BK 1775PG2590 148123 18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest In the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instru- ment. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not Tess than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Secu- rity Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. if Borrower meets certain conditions, Bor- rower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrow- er's right to reinstate; or (c) entry of a judgement enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of pro- tecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an insti- tution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects Period- ic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument,and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note,the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Fomi 3039 1/01 (page 11 of 14 pages) 3039-11.frm 10/00 mis • E3(1'775PG2591 148123 1» such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take correction action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Bor- rower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesti- cides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Envi- ronmental Cleanup. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazard- ous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Envi- ronmental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, law- suit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Envi- ronmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of re- lease of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. if Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration fol- lowing Borrower's breach of any covenant or agreement In this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Bor- rower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceler- ation of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert In the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its op- tion may require immediate payment in full of all sums secured by this Security Instrument without PENNSYLVANIA—Single Family --Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 (page 12 of 14 pages) 3039-12.frm 10/00 mis BK1775PG2592 148123 further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses Incurred in pursuing the remedies provided in this Section 22, inclu- ing, but not limited to, attorneys' fees and costs of title evidence to the extend permitted by Appli- cable Law. 23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instru- ment and the estate conveyed shall terminate and become void. After such occurrence, Lender shall dis- charge and satisfy this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 27. Interest Rate After Judgement. Borrower agrees that the interest rate payable after a judge- ment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. (Seal) JERE Y RUNKLE -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mac U [Fp�I�,iNSTRUMENT Form 3039 1/01 (page 13 of 14 pages) 3039-13.frm 10/00 mis �� ff r/ 5 PG 2 5 9 3 [Space Below This Line For Acknowledgement] Certificate of Residence 1, TINA FREIDHOF Mortgagee is P.O.BOX 2026 148123 , do hereby certify that the correct address of the within -named FLINT, MI 48501-2026 Witness my hand this 25th day of September , 2002 6()_, -A dA04 TINA FREIDHOF COMMONWEALTH OF PENNSYLVANIA, On this, the 25th day of September , 2002 , before me, the undersigned officer, personally appeared JEREMY RUNKLE for Mortgagee County ss: known to me (or satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. My Commission expires: Notarial Seal Glenda M. Wethington, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Dec. 27, 2002 Member, Pennsylvania Association of Notaries • PENNSYLVANIA --Single Family --Fannie Mae/Freddie Mao UNIFORM INSTRUMENT Form 3039 1/01 (page 14 of 14 pages) 5039-14.frm 10/00 mis BK 1775PC2594 • FIRST AMERICAN TITLE INSURANCE CO. • 4 Commitment Number: RUNK242-02R SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the westem line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastem fine of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty (40) feet to point on the southern line of Lot No. 265; thence in an easterly direction one hundred thirty-seven and ninety-seven hundredths (137.97) feet to a point in the west side of Deanhurst Avenue; thence southwardly along the western side of Deanhurst Avenue on hundred (100) feet to a point, the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumberland County in Plan book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan book 8, Page. 1 Certify this to be recorded In Cumberland County PA Recorder of Deeds ALTA Commitment (RUNK242-02R.PFDIRUNK242-02R14) Schedule C BK1775P62595 McCABE, WEISBERG & CONWAY, P.C. BY: Brian T. LaManna, Esquire Attorney Identification Number 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 Telephone: (215) 790-1010 Email: blamanna@mwc-law.com Attorneys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff, v. Jeremy Runkle a/k/a Jeremy M. Runkle, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7635 Civil Term MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. Issue Before The Court Plaintiff JPMorgan Chase Bank, National Association (hereinafter "Plaintiff'), files the instant Motion to Reassess Damages to respectfully request this Honorable Court amend the foreclosure judgment to accurately reflect the additional accrual of interest and the additional expenditure Plaintiff has made or incurred to preserve its security interest in a mortgaged property leading up to the Sheriff's sale. II. Question Presented Question: Should the Court permit Plaintiff, to amend its judgment in foreclosure in order to adequately reflect and include additional amounts incurred and due Plaintiff since the original entry of Default Judgment? Answer: Yes. III. Factual Background Defendant Jeremy Runkle a/k/a Jeremy M. Runkle (hereinafter "Defendant"), is the owner of property known as and located at 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011 (hereinafter "the Property"). Defendant executed a note (hereinafter "Note") and mortgage (hereinafter "Mortgage") in favor of Plaintiff s predecessor in interest, by which Defendant agreed to pay principal, interest, late charges, real estate taxes, homeowners insurance and other necessary costs as they became due. Please see attached Exhibit A and Exhibit E, respectively. The Note was secured by the Mortgage lien on the Property. Please see attached Exhibit E. The Mortgage was assigned to Plaintiff pursuant to the Assignment recorded in the Office of the Recorder of Deeds for Cumberland County as Instrument Number 201035739 and attached hereto as Exhibit B. The terms of the Mortgage provide that in the event of default, Plaintiff may advance necessary funds to protect its security interest in the Property, including but not limited to, payment of taxes and hazard insurance on the Property. Please see attached Exhibit E. On December 20, 2012, Plaintiff initiated the instant mortgage foreclosure action by filing a Complaint in Mortgage Foreclosure (hereinafter "the Complaint"), due to Defendant's failure to make the monthly payments as required by the Mortgage and the Note and on April 1, 2013, Default Judgment was entered by the Court against Defendant in the amount of $120,659.78. 2 Please see attached Exhibits C -D. The Property is currently scheduled for a Sheriff's sale on October 1, 2014. Since the filing of the Complaint and the subsequent Default Judgment, damages as previously assessed have become inaccurate and ineffectively reflect the actual amount currently due Plaintiff. As such, the judgment should be amended to reflect the additional interest, escrow advance, corporate advance and other expenses, which Plaintiff has been forced to incur and pay on Defendant's behalf or which have been otherwise assessed to protect Plaintiff's security interest in the Property. IV. Argument A. Standard of Review A mortgagee is required to petition the court and provide notice and an opportunity to be heard to mortgagors if mortgagee wants to increase the amount of a judgment before it is satisfied. Union National Bank of Pittsburgh v. Ciongoli, 407 Pa. Super. 171, 595 A.2d 179 (Pa. Super. 1991); Morgan Guar. Trust Co. of New York v. Mowl, 705 A.2d 923, 929 (Pa. Super. 1998), appeal denied, 556 Pa. 693, 727 A.2d 1121 (Pa. 1998) (mortgagee should petition the court for an amendment to the judgment prior to payment). If a mortgagee knows the amount of the judgment is incorrect and believes it necessary to reassess the amount of the damages, it should petition the court to amend the judgment prior to its satisfaction. Id.; see also Emc Mortg. Llc v. Biddle, 2013 Phila. Ct. Com. Pl. LEXIS 452, at *7 (Pa. C.P. 2013) ("[T]he right to seek amendment of damages prior to satisfaction of judgment has been repeatedly affirmed by the Superior Court"). 3 This Honorable Court should grant Plaintiff's Motion to Reassess Damages in the case at bar because Pennsylvania law specifically provides for the amendment of judgments in mortgage foreclosure actions and because the relief sought will not prejudice Defendant as the judgment is strictly in rem. B. Pennsylvania law specifically provides for the amendment of judgments in mortgage foreclosure actions Under Pennsylvania law, the Court may exercise its equitable powers to enforce judgment and grant any relief necessary until such judgment is satisfied. See Stephenson v. Butts, 187 Pa. Super. 55, 59, 142 A.2d 319, 321 (Pa. Super. 1958) (court may exercise power to control enforcement of judgment and may grant relief until judgment is discharged or satisfied); Chase Home Mortgage Corp. of the Southeast v. Good, 370 Pa. Super. 570, 537 A.2d 22 (Pa. Super. 1988) (damages may be reassessed in a mortgage foreclosure action before the satisfaction of judgment); PNC Bank, N.A. v. Unknown Heirs, 2007 PA Super 212, 227 n.3 (Pa. Super. Ct. 2007); 20 P.L.E. Judgments § 191. The right to seek the amendment of damages prior to satisfaction of judgment has repeatedly been affirmed by the Superior Court of Pennsylvania. See Nationsbanc Mortg. Corp. v. Grillo, 2003 PA Super 221 827 A.2d 489, 493 (Pa. Super. Ct. 2003) appeal denied, 577 Pa. 673 (Pa. 2004) (a mortgagee is entitled to petition the court to amend the writ of execution to include additional interest and costs prior to satisfaction of the judgment); see also, Mowl, 705 A.2d at 929; Ciongoli, 595 A.2d at 182. As Pennsylvania law has long recognized, a creditor must protect the collateral for its loan, up until the date of the Sheriff's sale because a mortgage is not extinguished until the debt is paid. Beckman v. Altoona Trust Co., 332 Pa. 545, 550, 2 A.2d 826, 828 (1939) ("The lien of a mortgage 4 continues until the mortgage debt is paid"); Good, 370 Pa. Super. at 574. The Supreme Court of Pennsylvania has stated that the debt owed pursuant to a mortgage is subject to change and should affirmatively be expected to change, because a creditor must advance monies for various expenses in order to protect its security interest in the property. Landau v. Western Pennsylvania National Bank, 445 Pa. 217, 226, 282 A.2d 335, 340 (Pa. 1971) ("The debt owed on the mortgage changed and can be expected to change from day to day"). It is particularly important to permit creditors to amend their judgments to reflect newly accrued fees and costs because of the in rem nature of a foreclosure judgment. Meco Realty Company v. Burns, 414 Pa. 495, 200 A.2d 869 (1964). An accurate judgment amount is absolutely crucial because plaintiff only recovers the amount of its judgment if a mortgaged property is sold to a third-party at a Sheriffs sale. In the instant case, the original judgment amount no longer adequately reflects the total amount due Plaintiff under the Mortgage. Interest on the debt has continued to accrue as a result of Defendant's ongoing failure to tender payments. The terms of the Mortgage are unequivocally clear in stating that Defendant was and is required to tender payments of principal and interest due on the outstanding debt and the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. The debt has not been satisfied and through its proposed amended judgment figure, Plaintiff is simply asking the Court to enforce the terms of the Note and Mortgage. The terms of the Mortgage also entitle Plaintiff to recoup the amounts it disbursed for taxes, insurance premiums and other necessary costs in order to protect its security interest in the Property. Beckman, 2 A.2d at 828; Good, 370 Pa. Super. at 574. The terms of the Note and 5 Mortgage are unequivocal and plainly state Defendant was and is required to tender payments to cover amounts due for taxes and insurance. Through Plaintiff's proposed amended judgment, Plaintiff is simply asking the Court to enforce the terms of the Note and Mortgage under Pennsylvania law. C. The relief sought will not prejudice Defendant because the foreclosure judgment is in rem In Pennsylvania, the sole purpose of retaining a judgment in foreclosure is to take the mortgaged property to Sheriffs sale to satisfy the judgment, interest and costs. Atl. Nat'l Trust L. L.C. v. Fonthill Corp., 2011 Pa. Dist. & Cnty. Dec. LEXIS 560 at *16-17 (Pa. County Ct. 2011) (citing Meco Realty Co., 200 A.2d at 871). Case law on this issue is exceedingly clear, holding that "[a]n action in mortgage foreclosure is an in rem proceeding, the purpose of which is to secure a judicial sale of the mortgaged property. Union National Bank of Little Rock v. Cobbs, 567 A.2d 719 (Pa. Super. 1989) (citing Fleet Real Estate Funding Corp. v. Smith, 366 Pa. Super. Ct. 116, 530 A.2d 919 (1987)); New York Guardian Mortgage Corp. v. Dietzel, 362 Pa. Super. 426, 429, 524 A.2d 951, 953 (1987) ("[a] judgment in a mortgage foreclosure action is not a judgment for money damages . . ."); US. Bank Nat 'l Ass 'n v. Lischuk, 2010 Pa. Dist. & Cnty. Dec. LEXIS 340 at *12 (Pa. County Ct. 2010). Pennsylvania Rules of Civil Procedure 1141-1150 govern actions for mortgage foreclosure and Pa.R.C.P. 1141(a) specifically provides that an action to foreclose a mortgage upon any estate or interest in land "shall not include an action to enforce a personal liability." (emphasis added). See also Newtown Village Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993) (It is well-established that an action in mortgage foreclosure is strictly in rem and thus may not include an in personam action to enforce personal liability); Insilco Corp. v. Rayburn, 374 Pa. 6 Super. 362, 368, 543 A.2d 120, 123 (Pa. Super. 1988); Signal Consumer Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978) (The very definition of a mortgage foreclosure action under Rule 1141(a) excludes "an action to enforce a personal liability"). Plaintiffs request to amend the judgment amount will not prejudice Defendant because Plaintiff's judgment remains strictly in rem for the purpose of effectuating a judicial sale of the mortgaged property. See Id. V. Relief Pennsylvania law explicitly provides for the amendment of foreclosure judgments prior to satisfaction, to accurately reflect the additional interest and any additional fees and costs a creditor makes to preserve its security interest in a mortgaged property prior to Sheriff's sale. Despite specifying a monetary sum, a foreclosure judgment is strictly in rem, and imputes no personal liability on a defendant in a foreclosure action. Accordingly, Plaintiff respectfully requests this Court order the judgment be amended as set forth above, order the Sheriff to amend the Writ nunc pro tunc as set forth above and for any other such relief as the Court deems necessary. Respectfull anna, Esquire ► , , e Weisberg & Conway, P.C. .rneys for Plaintiff 7 McCABE, WEISBERG & CONWAY, P.C. BY: Brian T. LaManna, Esquire Attorney Identification Number 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 Telephone: (215) 790-1010 Email: blamanna@mwc-law.com Attorneys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff, v. Jeremy Runkle a/k/a Jeremy M. Runkle, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7635 Civil Term CERTIFICATION OF SERVICE I, Brian T. LaManna, Esquire, hereby certify that I served or caused to be served, a true and correct copy of the foregoing Motion to Reassess Damages with Supporting Memorandum of Law, Exhibits and Proposed Order, by United States Mail, first class, postage prepaid, this the 6th day of August 2014, upon the following: Jeremy Runkle a/k/a Jeremy M. Runkle 204 Deanhurst Avenue Camp Hill, Pennsylvania 17011 Pro Se Defendant anna, Esquire cC.f Weisberg & Conway, P.C. Atty eys for Plaintiff JPMorgan Chase Bank, National Association Plaintiff, v. Jeremy Runkle a/k/a Jeremy M. Runkle, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7635 Civil Term ORDER TO REASSESS DAMAGES AND NOW, this / 3 ` day of Air '- 2014, the Prothonotary is ORDERED to amend the in rem judgment and the Sheriff is ORDERED to amend the Writ nunc pro tunc in this case as follows: Principal Balance Interest through 08/06/14 Escrow Advance Recoverable Balance Property Preservation Property Inspections Attorney Fees Attorney Costs Late Charges Suspense Balance REASSESSED TOTAL $ 101,444.05 $ 22,512.88 $ 11,369.83 $ 6,262.49 $ 188.77 $ 243.00 $ 3,545.00 $ 4,292.75 $ 113.34 $ -52.00 $ 149,920.11 Plus interest from August 7, 2014, through the date of sale. BY THE COURT: Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED -OF 2014DEC 31 Phi 2: 39 CUMBERLAND COUNTY PENNSYLVANIA OFF1GE OF 'NE SHERIFF JPMorgan Chase Bank, NA vs. Jeremy Runkle AKA Jeremy M. Runkle Case Number 2012-7635 SHERIFF'S RETURN OF SERVICE 01/08/2014 02:30 PM - Deputy Valerie Weary, 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 204 Deanhurst Avenue, Camp Hill - Borough, Camp Hill, PA 17011, Cumberland County. 01/31/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jeremy Runkle a/k/a Jeremy M. Runkle, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 204 Deanhurst Avenue, Camp Hill, PA 17011, address is vacant, defendant did not leave a forwarding address with the post office. 03/10/2014 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/7/2014 05/02/2014 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 05/16/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jeremy Runkle AKA Jeremy M. Runkle, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 45 West King Street, Shippensburg, PA 17257, per property manager at address stated, defendant moved out approximately one year ago. cab. 07/02/2014 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 08/06/2014 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 10/01/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on October 01, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Terrance McCabe on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,144.53 SO ANSWERS, November 03, 2014 RONIN R ANDERSON, SHERIFF (c) CountySu to Sheriff, Teleosolt. inc. %.0D � . nd Co j 3 /s -/iv WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-7635 Civil 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 JEREMY RUNKLE A/K/A JEREMY M. RUNKLE (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: $120,659.78 L.L.: Interest FROM 3/23/13 - $6,900.84 AT 519.83 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,165.76 Other Costs: Plaintiff Paid: Date: 11/5/13 (Seal) REQUESTING PARTY: Name: MARC S. WEISBERG, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 David D. Buell, Prothonota Deputy TRUE CO;FY FROM RECORD In Testimony whereof, I -here unto set my hand and the seal of said C;ourt.at Carlisle, Pa) 3 This S day of �/Oti, , 20 Prothonotary "4,td_______ Io G fNoi-o-w LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2012-7635 Civil Term JPMorgan Chase Bank, N.A. vs. Jeremy Runkle aka Jeremy M. Runkle Atty.: Terrance McCabe ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty (40) feet to point on the southern line of Lot No. 265; thence in an easterly direction one hundred thirty-seven and ninety- seven hundredths (137.97) feet to a point in the west side of Deanhurst Avenue; thence southwardly along the western side of Deanhurst Av- enue one hundred (100) feet to a point, the place of BEGINNING. BEING No. 266 on the Plan of Chartiers Place as recorded in the Cumberland County Recorder's Of- fice in Plan Book 2, Page 69, and as corrected by subsequent Plan of a portion thereof recorded in Cumber- land County in Plan Book 6 Page 35. See also Plan recorded on July 10, 1956 in Plan Book 8 Page. 204 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. BEING the same premises which JEREMY M. RUNKLE AND DAMN M. RUNKLE, HIS WIFE by deed dated September 25, 2002 and recorded October 2, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 253, Page 4280, 69 granted and conveyed to Jeremy M. Runkle, married man, in fee. TAX MAP PARCEL NUMBER: 01220533050. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. *YAAr.' ".••••••••••••••• Lisa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot -News Co. 2020 Technology Pkwy Suite' 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 hc atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2012-7635 Civil m J Morgan Chase ank, NA Vs • Jeremy Runkle AKA Jeremy M. Runkle Atty: Terrance McCabe ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the western line of Deanhurst Avenue and on the northern line of Lot No. 267 of the hereinafter mentioned Plan of Lots; thence along said northern line of Lot No. 267 westwardly one hundred sixteen and seventy-eight hundredths (116.78) feet to a point on the eastern line of Lot No. 264; thence northwardly along the eastern line of Lot No. 264 and the eastern line of Lot No. 261 forty (40) feet to .point on the sc, n n ,;;,e of Lot No. 265; thence in an easterly direction one hundred thirty-seven and ninety- ,(ii70)feet to a_1 This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 o -nd subscribed before m this 18 day of February, 2014 A.D. ry ' blic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel Notary Washington TWDauphinou ny My Commission px. esDec. County MEMBER, PEN LVAN A S� = 12 2016 ON 'NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mtg Assoc is the grantee the same having been sold to said grantee on the 1st day of October A.D., 2014, under and by virtue of a writ Execution issued on the 5th day of November, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 7635, at the suit of JPMorgan Chase Bank N A against Jeremy Runkle aka Jeremy M Runkle is duly recorded as Instrument Number 201430364. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this �/ day of , A.D. <2 O / 4/ /I/ 74<::" ' ecorder of Deeds • ecord • eeds, Cumberland County, Carlisle, PA My Com fission Expires the First Monday of Jan. 2018