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HomeMy WebLinkAbout13-0858UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 AGNES MOMBRUN, ESQUIRE - ID#309356 ELANA B. FLEHINGER, ESQUIRE - Il}#209197 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 NICHOLAS GAUNCE, ESQUIRE - ID#206228 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren_cnm The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. LEEANNSHANABROUGH 204-206 9TH STREET NEW CUMBERLAND, PA 17070 MATTHEW P. SHANABROUGH 206 9TH STREET NEW CUMBERLAND, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF -:~ «~ ~~ ~ -'~ r*~ ~~ w ~, ~' ._, ~y ~ ~-- ~; :! e=~ ,~, ~ r~ ~_ °• ...~ r~ v~ s- COURT OF COMMON PLEAS CIVII. DIVISION CUMBERLAND County ~ ~~</ NO. I ~ - ~~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other ~` . -~:.Y, c's" ~~ ~w c~ -- a. r, ~ ~:- r., ~~- C a~~~ ~ ~ .7S ~ a u~/S~ ~~ -~ ~ a~s~~ claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de 1a fecha de la demanda y la notification. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IM1~~EDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856)669-5400 Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Equity One, Incorporated Assignee: The Bank of New York Mellon f/k/a The Bank of New York as successor in interest to JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 Date of Assignment: 07/02/2012 Recorded Date: 11/13/2012 Book/Instrument #: Instrument# 201234917 Page: NA Assignor: The Bank of New York Mellon f/k/a The Bank of New York as successor in interest to JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 Assignee: The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 Date of Assignment: 12/07/2012 Recorded Date: Book/Instrument #: Page: 2. Upon information and belief Defendant(s) and/or their predecessor: Matthew P. Shanabrough 1 hereinafter "Defendants"), are the owners of property located at 204-206 9th Street, New Cumberland, PA 1.7070 , by virtue of Deed dated 02/17/2006 and recorded 03/13/2006 in Official Records Book 273 at Page 2645 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 04/21/2004 ,Defendant(s) and/or their predecessor: MATTHEW P. SHANABROUGH promised to pay to the order of Equity One, Incorporated ,the principal sum of $124,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 04/21/2004 ,Defendant(s) and/or their predecessor: MATTHEW P. SHANABROUGH LEEANNSHANABROUGH to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Equity One, Incorporated , the Property which is the subject of this action. The Mortgage was recorded on 08/18/2004 in Official Records Book 1877 at Page 3552. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 01/01/2012, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $111,946.66 Accumulated Interest $7,787 39 Accumulated Late Charges $164.60 Other Suspense Balance $-311.03 Title Report $300.00 Attorney Fees $1,650.00 Property Inspection Fee $52.50 Property Valuation Fee - BPO $584.00 Grand Total $122,174.12 The above figures are calculated as of 12/04/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.96000 %. The per diem interest accruing on this debt is $21.23 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $41.15. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $122,174.12 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY----~_-a~ -" KASSIA F'At Vnrc `QUIRE P~ iu :iiU530 VERIFICATION The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn Date: ~"~S " ~~`~ Company: Ocwen Loan Servicing, LLC as attorney in fact for The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 MJU #: 12040498 CASE #: 12040498-1 Title: Contract Management Coordinator ~~ ~~ t r[,Rr~~t~ ~~e~`jY~ f4yT~li~~li(`1 5~~![~~C ~~~ ~~~~ ~~ ~~ ~a~ ~!~ ~i~ 1 J~~ Ip ~~ ~~ ~~~ ~, ~~~.~. ~~~ ~ ~~~~~ ~~~ ~~~ ~~ ~~~~~ * , ~~ ~ ~ ~; ~ ~ ~, ~~ ~ ~~ ~~~~ ~' ~ ~'"~ ~~ ~~~1 ~ ~~~ ~ ~~' ~~~ ~~ ~~~ ~~~~ ~~~~ M rw ~~Q~ ~i~ ~t~ ~~~ 5 October 17, 2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the. mort~a~e on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pales. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Aaency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are Iisted at the end of this Notice. If you have any puestions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearinE can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD3UNT0 ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDINIIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CUKRENT LENDER: Matthew P Shanabrough Leeann Shanabrough - -------.T_.~..____-__----.....____------- 204-206 9th Street New Cumberland, PA 17070 ~_~ _____ ___.__.___.__..._ 7090970760 Popular Financial Services, LLC ___ ____ The Bank of New York Mellon f/k!a The Bank of New York as successor in interest to JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certifcatehoiders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 __,__- --- _- ___ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 {THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BT' THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30} days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (331 DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COIJNSELL'~1G AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. T'he names, addresses and telephone numbers of designated consumer credit counseling~Lncies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.} To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHPA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under`the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (b0) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT f Bring ~t up to date NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 204206 9th Street New Cumberland, PA 17071) IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $822.97 for January Ir 2012 through October 1_, 2012 = $_82229.70 ____ Late Charles =$288.05 ~~ __ ___ _ Other charges (explain/itemize): Property Valuation Fees/BPO = $584.00 ~"-~""""~~~"-____..~___. Property Inspection Fees = $42.00 Suspense BatancelCredit=-$31.1.03_ _ _ _____ _ TOTAL AMOUNT PAST DUE: ~~ _~_~~____~~__~^~ ~~~~_ $8,832.72__ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable); N/A HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $8,832.721 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made payable and sent to• Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road. Suite 200 Cherry Hill, NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.l: N/A IF YOU DO NOT CURE THE DEFAULT - If you da not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasanable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you care the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all ather sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You. may do so by Having the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Shenff s Sale as specified in writing by the lender and by performing any other requirements under the mortcaue. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Saie of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the SherifFs Sale will be sent to you before the sale. Of course, the amount needed to cure the default v~~ill increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of LenderlServicer: Ocwen Loan Servicing, LLC _ Address: 1661 Worthington. Road Suite 100 West Palm Beac FL 33409 hz_____ _...__...._.~..____....._____..._..-._._.._.__.-._.__. Phone Number: 877-596-85_80 Fas Number: 407-737-5693 --- --~ -------------_.___....._...._.._.. Contact Person: Customer Service E-1VIail Address: ----------.--.__..__. __--__.-__._____.___.__~. EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and ,your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may have the right to transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. if you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once. we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry HiII, NJ' 08003-3620 (856) 669-54E10 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDLNG INSTIT[JTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCL7RRED, IF YOU CURE THE DEFAULT. {HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THIZEE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDIIvG OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY H~MAP Consumer Credit Counseling Agencies CL`MBERLAND County Report last updated; 08!17."20; Z 11:26 AM Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717-232-9757 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 88$-511-2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 1.7268 717-762-3285 PHFA 21 I North Front Street Harrisburg, PA I7I IO 7I7-7$0-3940 $00-342-2397 PA Interfaith Community Programs I'nc 40 E High Street Gettysburg, PA 17325 717-334-1518 ,~. s ., _....... . ~ ~ 1.J LJRGIY ~/'7YY 4.~{~r!'"E~, ~ U. - , s~ ~, ~ ~' 1NQt3DCREST COi~pt~~t= i'> i~E.~i?'ER ~.~~ ~ ~; ~. ' _! 111 WOOCICREST RUHI~ ,~ •,~ °~- '~ ,~ ~, CHERRY HILL, NJ 08003 , ~} `l: ~ 77,2 7,640 Oti~O 5278 4456 -N~ 5~-A ~+ A ac~i>c~ ~~ 2 ~-t - Z.~tc q ~` S-~2Ec T v~ C. ~N.~~~Np ~ PA l~o~-o C)4ri-f2a~,i9~"ice ~~~.~~ ltt'tf i 'i)i l}S €~,:~~1,~xt~E M Complete items 1, 2, and 3. Also complete item 4 if Restricted belivery is desired. • Print your Hama and address on the reverse so that we can return the card to you. rrA Attach this card to the back of the maiipiece, or on the front if space permits. l 1. Article Addressed to: l..t~ tJ I~l ~ A>,AB2D~ t-1 - 2ty-F-2ofo `~'µ S~2EE-f ~~ C~ r~.c3E~l.~~N~~ PA i~o~c~ ,. s A. Signature X D (lgent ^ Addressee l3. Received by (Printed Name} C. Date of Delivery D. Is delivery address dfflerent from item t7 O Yes !f YES, enter delivery address below: D No 3. Service Typ@ i~'Certified Mall O Express Mail ~ Registered ~ Return Receipt for Merchandise ^ insured Mali O C.O.D. 4. Restricted Delivery? (Extra Fee) p Yea ?. Art~Nurnber 7d],2 16411 dd~D 52?8 4456 (TFansfer rrom servrce rabeq PS Form 3811, February 20p4 Domestic Return Receipt ~o25as-o2-Masao ~ ___ _ _ ~ t UI~I2EN LAW dFr~~`~S: ~? C. ! • f +~ ~ i~' Wt9ODCR~STCORPUh~t 7~ ~E~TE~2 ~: ,~~ 111 i .yet ,i, tl` ~.~ ~~ , Wt]4DCREST ROi~C3 i ,{~~;. ~ ~ - -.. ~;.HERR`~ HI~.L, RfJ 08003 i ~...~ ~ ~ ~,i 'i '~ ~ ; ~ u~.y. ~ f'ti~T~tt.~L 712 164[] L1000 5278 4487 Nt~T-c~~~ l,~,. 1 SN~Nac-~vc;, N ~ ~' i ~ ~ S TYa.c~c 4 (~1~.,J CAN. $~a~a ~, P A i ~}b ~u~~ou-4~t-i ~~,-. „~._...- ^ Complete Items 1, 2, and 3. Also complete Item 4 if Restricted i~livery Is deskrad. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front ff space permits. i. Article Addressed to: !w~-r-c~~..a ~P S~r~~ ~a~u ~> li Zcy-~ k-`t'" SST f,. A. Signature ~ Avert ~( D Addressee B: Received by; Prlntad Name) G. Data of Delivery D. is depvery address different from item 1? D Yes If YES, enter delivery address below: 0 No 3. Service Type . $ CeNfied Map O Express MaU ~ Registered ~iaturn Receipt for Merchandise ^ Insured Map O C.O.D. B. Restricted Delivery? (Extra Fee) ^ Yes i Ar~ic~eNumbar 7Q12 3,b4C1 Ql7QQ 5278 4487 (>iansfer from service label) tozsss•oa-ta•t5ao h PS Form 3811, February 2004 pomestio Return Receipt ~~ ;. J ~ ~. r' VI7REN LAV1f ~~"t'~rS. ?. C. 111/ IIIii~1111 ~~~~~~~~ a iii ^^u...~. ^~. t WOOdCE~E$TCORPUF;r. "~~JTER ~ 1'11 WOODCREST Rt;~:,u i Gl-fEFiRY HII.~, NJ 06003 i s ?[l12 164^ ClCI~Q 578 446.3 ~µ-r~rNF~J ~ ~NA~A1Cs,N ~ ~- ~:;,~. ,~ : jam,. ~. ~• CtieiH-=4519?~8 • l.~e.).~~„~ ~v~~ cwt ~i 6~ 1 ~ cz` _.. s ^ Complete items 1, 2, and 3. Also complete Nem 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the flack of the maiipiece, or on the front If space pertnlts. ' 1, Artlde Addressed t7o-~ +v,l4TTaa`ic.~ ~"'" S4tANP.E~2~y.:Gtbl 2c~{ -let, 9T~* 5 rt2c-~T ~w ~., w.~-Nn i ~A- 1 ~o~-c A. Signature X O n®ent ^ Addressee 8. Received by (Printed Namej C. Date of Delivery D. is delivery address different from Item t T D Yes If YES, enter delivery address below: ^ No 3. Service 75rpe ~Certlfled Mafl D Fartpress Maii ^ Registered B~Fietum Receipt for Merchandise ^ Insured Mall ^ G.Q.D. 4. Restricted DeNvery? (Extra Fee) ^ Y~ 2. Article Number (Transfer frW» sendce labeQ ?' 0~ 2 16 4 D D D D D 5 2 7 8 4 4 6 3 P5 Form 3811, February 2004 Domestic Return Receipt ~o25es-o2-M-t54o UCIREN LAW'?~"~~~'~S, PC. WOODCREST CORPt;r~ ~~ ~r- ~~=,dTEt~ 111 WOODCREST RONl7 CHERRY HILL. NJ 08003 ~ ~ _I 1 ~.^ 4 1 1 ~s 712 1644 C1~~0 5278 447[l ~ 1 ti~..~ C~~..a~~-~~, ~a ~~-~~ C•f.OH265~9•t _~ ~s t.r~ {~~~~T~~~~ r~.o~-to~t4b~l ~.~T _. r ~ ~ - ~ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ^ Print your name and address on the reverse so that we can return the card to you. >! At#ach this card to the back of the mafipiece, or on the front if space permifs. 7. Anita Addressed to: C~=-~aa-.~ ~aN~rtsr~~~-.~ t=.ik ~Ea..t3 CJiu~~~i P~} 1TV'~-i~ A, Signature X ~ Agent __ _ © Addressee B. Recehred by (Prlreted Name) ~ C. Data of Delivery D. is delivery address different from Item 77 D Yes If YES, enter delivery address below: ^ No ~ ~~ 3. Servke Type ~ertlfled MaU ^ Facpreas Mail ~ Registered ~ Return Receipt for Merchandise O insured Mall ~ C.O.D. 4. Restricted Delivery? (Extra Pee) ^ y~ 2. AnicteNumber 7D1,2 1i~4D DDDD 5278 447D (transfer~rom service label _._._...__.--------_____.._ o PS Form 38f 1, February 2004 Domestic Return Receipt 102595.02-M-tfi40 ! wooacs~r s~- coRpo~>~, ~ . ~:r~r~l~ 111 W()CipC~EuT ROAD CNERFZY NILL, NJ 08003 • , j _ ,~ ~ ~` ,.x.? ~^ i~a. 7C17,~ 1,64CI C1~0~ 5C?8 450[1 lob ~-nk 5-~-r tYt)ti tiJ~`'t/~jp 1, ~ ~ I i;-"I lei{_! + _ ~ .iii;+~i3 ~.t i~._. s t A O is ~ 2d~ o~ [ $-- i fl-c--C ~ -- j T. II~REN LAW r~~s:`~~S, F'.C, r'.~~~~F ~.•~°,~° ritFri,~,.FF}9~1h WOODCRE~ i GQRPU~'a''~ i':ENTER ' ~`~ ~ ~_`~ ?11 `JVOUDC;REST ftUA~ r~ ~~,~ ~ t' ~~.~~~ NJ 08003 ~~ n ~'+ f ~ ~:HQl~tRYHlLL. ', ss~'~~ .;~'.. , ~ ~ r4?1~E~,F'f=;ii1' t}~;jtf;3 7Q12 7,64[] QQ[lQ 5278 4494 2c.~ R -~ ~T~~~ 1Za~}p~k~l8-1 ;~kr~T w Gomp[eta Items 1, 2, and 3. AEso complete liem'4 if Restricted Delivery is desired. w Print your name and address on the reverse so that we can return the card to you. w Attach this card to the back of the mailpiece, or on the front if space permfts. t. Amble Addressed to: L~RNt~ ~+.-tAa~€~2avCo~t N~~..~ C~e~w~a~o~~~ Imo A. Signature X ^ Agent ^ adaressee B. Received by (Printed Name) C. Dete of Depvery D. Is depvery address different from item 1? ^ Yes !f YES, enter delivery address below: ^ No 3. Servbe Type ~ Certified Map D Express Mail ' ^ Registered Return Receipt for Merohendise ^ Insured Map ^ C.q.D. 4. Restricted DelNeryl (Extra Fee) ^ Yes 2. Article Number . (transfer from servrce label) 7 C11i 2 16 4 0 ^ 0 0 0 527 8 4 4 9 4 PS Form 3811, February 2U04 Domestic Reiurn Receipt 102685-o2-ta-1640 ~; -T- _ ~ ^ Complete items 1, 2, and 3. Also complete A. Signature Item 4 If Restricted Delivery is desired. D Agent X ^ print your name and address on the reverse ^ Addressee so that we can return the card to you. a Attaeh this card to the back of the mailpiace, B. Received by (Printed Name) C. Date of Delivery or on the front ff space permits. 1 . Amide Addressed to: D, is delivery address different from item 1? ^ Yes . If YES, enter delivery address below: ^ No 'ZiJb `~ T~ c~-.ce~~-r ~~~ ~~~~a~l ,gip (~c~~-o .. s. servt~e;vpe a . ~1:ceraaed Mail ^ Express Mall ^ Registered $ Return Receipt for Merohandlse ^ Insured MaU D C.O.D. 4. ResWcted Delivery? (Extra Fee) ^ Yes z. Arad@ Nwnber __ 7 [l 12 (Transfer from service taben 1.6 4 [] (J Q C] 0 5 2 7 4 4 5 0 0 -._~.___..___......_..._.._ ._._._._...__ ........ __ _......- -- ............... ~ PS l=oan 3811. February 2004 Dompsae Return Receipt 102595-02-M-1640 ;I ~, ~~a+r1IG o~ ~ p W `i o ~ ~ /~,~ Il D~ Plaintiff(s) vs. Defendant(s) FORM 1 ~- c~ II~' THE COURT OF COMMON PLEAS OF ~ ~ - -~ .-4~ CUMBERLAND COUNTY, PENNSYLV -"'n ~"'`~ "" r--~ .. . _ G' ~ r 'Ti ~ ~ 1 ~ ~ ~~ Civil . J ~ v --+ ~ ... MORTGAGE FORECLOSU RE _ . NOTICE OF RESIDENTIAL DIVERSION PROGRAM You have been served with. a foreclosure complaint that could cause you to lose your home. If you awn and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supen~ised co~rciliation conference in an effort to resolve this matter with your lender. If you do not Gave a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twent}' (20} days of your receipt of this notice, you must contact MidPenn Legal Sen~ices at (7] i) 443-9400 extension '?~ 10 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 sen~ice 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 uy a lawyer, yon 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 far 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 si~:ty (60) days of the service upon you of the foreclosure complaint. Tf 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 TIIE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: ~- 1~-~/~ Date s- -~'-' [Signature of Counsel for Plaintiff) KASSIA FIALKOFF, ESQ!)IR,[ PA ID 310530 FORM 2 Cumberland CountS~ Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date _ Cumberland County Court of Common Pleas Docket # BORROWF,R REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the follouing information to the best of your knowledge: Borrower name(s): Property Address: Citti•: Is the property for sale? Realtor Name: Borrower Occupied.? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: Mailing Address: City Phone Numbers: Email: # of people in household.: State: Zip: Yes ^ No ^ Listing date: Price: $_ Realtor Phone:_ Yes ^ No ^ Home: Cell: How long? State: Zip: Home: Office: Cell: Other: How long? First Mortgage Lender: Type of Loazl: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Priman~ Reason for Default: State: Zip: Office: Other; Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #I: iv4odel: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation. (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. ~i, ?. ~. Additional Income Description (n.ot wages): I . monthly amount: ? monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE A1vI0UNT EXPENSE AMOUNT Mortaave Food 2" Mort ~a~le Utilities Car Payment(s) CandoJNei h. Fees Auto [nsurance Med. (not covered) Auto fuel/re airs Other ro ayment Install. Loan Pa ~ment Cable Tv Child Su ort/Alim. S endin Money Day/Child Care/Tuit. Other Ex enses I Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax:_ Email: Have you made application for Homeowners Emergency Mortgage assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes. please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (I~Tame): Phone: Servicing Company (Name): Contact: Phone: I/We, ,authorize the above named to use/refer this information to my lender!sen~icer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am,`are under no obligation to use the sen~ices provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document. along with the following inf©rmation to lender and lend__ettr's counsel: _Vj Proof of income _V Past 2 bank statements -V Proof of any expected income for the last 45 days _V( Capy of a current utility bill -V .Letter explaining reason for delinquency and any supporting documentation {hardship letter) Listing agreement {if property is currently on the market) FORM 3 ~ h1L~ank ~(~ 'h~ ~ `~~~ ~ ~~'le (~ oh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL,Vr~N1A Plaintiff(s) VS. I ~¢~h~ 5~~,~ ~,b~~~ ~ ~.+~I Defendant(s) CIV1_I. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012. governing the Cumberland Count~~ Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certif es as follo~~-s: 1. Defendant is the owner of the real property «~hich is the subject of this mortgage foreclosure action; '?. Defendant lives in the subject real property, which is defendant's prrmary residence; >. Defendant has been served with a '`Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required. in that. Notice to be eligible to participate in acourt-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. 1 understand that false statements are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Late Signature of Defendant Date UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEGS ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 NICHOLAS GAUNCE, ESQUIRE - ID#206228 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadin s udren.com _ The Bank of New York Mellon f/k/a The Bank of ~ COURT OF COMMON PLEAS New York as successor trustee for JPMorgan Chase 'CIVIL DIVISION Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 Plaintiff v. Leeann Shanabrough 204-206 9th Street New Cumberland, PA 17070 Matthew P. Shanabrough 204-206 9th Street New Cumberland, PA 17070 Defendant(s) ~, CUMBERLAND County II _ l ~! NO. C I ~ 3 ~s ~ ENTRY OF APPEARANCE TO THE PROTHONOTARY: ~._ t-M~ ~ . ~:_ ,~ ~ ~:`~'« sus a~ ~~--. ~rt . ,. ~:, ~:w: ~ ~~' ~ a~"t, -, ...- Q~ ~» Q •_t, ~~ _,- w - Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; "~ beth L. Walsall, Esquire; Esquire; Katherine E Knowlton, Esquire; Nicholas Gaunce, Esquire, and John Eric Kishbaugh, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. BY: ~_ ATTORNEY FOR PLAINTIFF KASSIA FIALKOFF, ESQUIkE PA ID 310530 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A., as Trustee Cumberland County ' for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through , Certificates Series 2004-5 NO. 13-858 Civil ._ Plaintiff V. C, _ LEEANN SHANABROUGH; `i MATTHEW P. SHANABROUGH; et al Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: UDREN LAW OFFICES, P.C. BY: Atto eys for PI ' iff HARRY B. REESE, ESQUIRE PA ID 310501 Vim•` G SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff .°'� OF THE PROTNONOTAR'f � ��p at�uebrtra�y� Jody S Smith 2013 APR 15 AM 9: 24 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor WCE OF TME SKRIFF PENNSYLVANIA The Bank of New York Mellon,f/k/a The Bank of New York as successor Case Number vs. 2013-858 Leeann Shanabrough ; et al(et al.) SHERIFF'S RETURN OF SERVICE 03/21/2013 Ronny R Anderson, Sheriff, being duly swom according to law,states he made diligent search and inquiry for the within named Defendant to wit: Matthew Shanabrough, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure as"Not Found"at 204-206 9th Street, New Cumberland Boro, New Cumberland, PA 17070. 03/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew Shanabrough, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found"at 204 9th Street, New Cumberland Boro, New Cumberland, PA 17070. Deputies were informed by a neighbor that 204 is thought to be occupied by a tenant but deputies were unable to make contact with anyone at the address before the Complaint expired. 03/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Leeann Shanabrough ;et al, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 204-206 9th Street, New Cumberland Boro, New Cumberland, PA 17070. 03/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Leeann Shanabrough ;et al, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 204 9th Street, New Cumberland Boro, New Cumberland, PA 17070. Deputies were informed by a neighbor that 204 is thought to be occupied by a tenant but deputies were unable to make contact with anyone at the address before the Complaint expired. 03/21/2013 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry for the within named Defendant to wit: Leeann Shanabrough ;et al, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure as"Not Found"at 206 9th Street, New Cumberland Boro, New Cumberland, PA 17070. Residence is vacant. 03/21/2013 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew Shanabrough, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure as"Not Found"at 206 9th Street, New Cumberland Boro, New Cumberland, PA 17070. Residence is vacant. SHERIFF COST: $165.00 SO ANSWERS, April 11, 2013 RbNIrY R ANDERSON, SHERIFF {c}CountySuite Sheriff,Teleosoff,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Of.- F11 ED-OF F IGE Sheriff t V ( #OT AY nt : Jody S Smith a LV Chief Deputy 7013 APR 18 Pfd l2t 52 Richard W Stewart CUNi6ERLANp COUNTY Solicitor °°"crorc esµsneE PENNSYLVANIA The Bank of New York Mellon, f/k/a The Bank of New York as successor Case Number VS. Leeann Shanabrough ; et al let al.) 2013-858 SHERIFF'S RETURN OF SERVICE 03/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Leeann Shanabrough; et al, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 04/05/2013 05:22 PM -The requested Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Erlyne Schneider, Mother of defendant,who accepted for Leeann Shanabrough ; et al, at 345 Nursey Road, Wellsville, PA 17365. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 04/09/2013 03:34 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Angela Shanabrough, Wife of defendant, who accepted as"Adult Person in Charge"for Matthew Shanabrough at 301 Cheryl Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055��` RYAN BURGETT, DEP SHERIFF COST: $63.00 SO ANSWERS, April 16, 2013 RONWY R ANDERSON, SHERIFF (c)Countv5uitm SWfr TeIurmn.Inc SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerteber PETER J.MANGAN, ESQ. Sheriff _y Solicitor m� Reuben B Zeager Richard E Rice,II Chief Deputy, Operations Chief Deputy,Administration THE BANK OF NEW YORK MELLON flkfa THE BANK OF NEW YORKAS Case Number SUCCESSOR TR vs. 13-858 CIVIL LEEANN SHANABROUGH SHERIFF'S RETURN OF SERVICE 04105/2013 05:22 PM-DEPUTY HOLLY RODE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE(CIMF) BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE ERLYNE SCHNEIDER, MOTHER, WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR LEEANN SHANABROUGH AT 345 NURSEY ROAD, WELLSVILLE, PA 1 7365. J� Q�� i 1Vl1U HOLLY ROODS; DEPUTY SHERIFF COST: $43.34 AS ACTING SHERIFF FOR April 11, 2013 RICHARD P KEUERLEBER, SHERIFF -------- --- -..... NOTARY Affirmed and subscribed to before me this 11TH day of APRIL 2013 OOM , (c)oountySOe ShedR,Toia ,,fl,Inc, NOTARIAL BEAT, LIBA L.TNORPE.NOTARY PUBLIC CITY OF YORK.YORK COUNTY MY COMMISSION EXPIRES AUG. 12,2013 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com The Bank of New York Mellon f/k/a The Bank of New York COURT OF COMMON PLEAS as successor trustee for JPMorgan Chase Bank,N.A.,as CIVIL DIVISION Trustee for the benefit of the Certificateholders of Popular Cumberland County ABS,Inc.Mortgage Pass-Through Certificates Series 2004-5 1661 Worthington Road,Suite 100 MORTGAGE FORECLOSURE,-; r , West Palm Beach,FL 33409 T Plaintiff rn v. NO. 13-858 Civil n LEEANN SHANABROUGH z" • 345 NURSERY ROAD c-- ' WELLSVILLE,PA 17365 MATTHEW P. SHANABROUGH D ` c 301 CHERYL AVENUE MECHANICSBURG,PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), LEEANN SHANABROUGH; MATTHEW P. SHANABROUGH; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises,and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $111,946.66 Interest Per Complaint $7,787.39 Additional Interest 12/05/2012 06/25/2013 $4,309.69 Late Charges Per Complaint $164.60 Additional Late Charges 12/05/2012 06/25/2013 $288.05 Other Suspense Balance $-311.03 Title Report $300.00 Attorney Fees $1,650.00 Property Inspection Fee $52.50 Property Valuation Fee-BPO $584.00 Grand Total $126,771.86 I hereby certify that(1)the addresses of the Plaintiff and Defendant are as shown above, and(2)that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. N L• • '.C. BY: t i l. . : ren E� ul . e • Pla : UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY:MARK J.UDREN,ESQUIRE-ID#04302 STUART WINNEG,ESQUIRE-ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE -ID#90675 SALVATORE CAROLLO,ESQUIRE-ID#311050 PAIGE M. BELLINO,ESQUIRE-ID#309091. HARRY B.REESE,ESQUIRE-ID#310501 KASSIA FIALKOFF,ESQUIRE-ID#310530 ELIZABETH L.WASSALL,ESQUIRE-ID#77788 COPY AGNES MOMBRUN,ESQUIRE-ID#309356 ELANA B.FLEHINGER,ESQUIRE-ID#209197 KATHERINE E.KNOWLTON,ESQUIRE-ID#311713 NICHOLAS GAUNCE,ESQUIRE ID#206228 JOHN ERIC KISHBAUGH,ESQUIRE-ID#33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 °�` *t - r 856-669-5400 pleadings The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS ° - . =r' Bank of New York as successor trustee for CIVIL DIVISION n - JPMorgan Chase Bank,N.A.,as Trustee ' CUMBERLAND County if for the benefit of the Certificateholders of '' Popular ABS,Inc.Mortgage Pass-Through ; 2< ��d/f _< - Certificates Series 2004-S NO. O JU C/O Ocwen Loan Servicing,LLC 1661 Worthington Road Suite 100 West Palm Beach,FL 33409 Plaintiff v. LEEANN SHANABROUGH 204-206 9TH STREET NEW CUMBERLAND,PA 17070 MATTHEW P.SHANABROUGH 206 9TH STREET NEW CUMBERLAND,PA 17070 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages. you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �U;titg,nt Citttuw„,pfd Jody S Smith . , Chief Deputy . Richard W Stewart Solicitor or-s,;:;r .'T 4 4846RIP: The Bank of New York Mellon,f/kla The Bank of New York as successor Case Number vs. Leeann Shanabrough ;et al (et al.) 2013-858 SHERIFF'S RETURN OF SERVICE 03/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Leeann Shanabrough ;et al, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 04/05/2013 05:22 PM-The requested Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Erlyne Schneider, Mother of defendant,who accepted for Leeann Shanabrough ; et al,at 345 Nursey Road,Wellsville,PA 17365. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 04/09/2013 03:34 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Angela Shanabrough, Wife of defendant,who accepted as"Adult Person in Charge"for Matthew Shanabrough at 301 Cheryl Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055. RYAN BURGETT, DEP SHERIFF COST: $63.00 SO ANSWERS, April 16,2013 RONIR ANDERSON, SHERIFF {c1 Goun!ySulte&henti.7eleosof.Inc. SHERIFFS OFFICE OF YORK COUNTY Richard P Keuerieber e�9 's PETER Solicitor PETER J.MANGAN, ESQ. Sheriff / M► Reuben B Zeager , . Richard E Rice,II Chief Deputy, Operations c Chief Deputy,Administration THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK AS Case Number SUCCESSOR TR 13-858 CIVIL vs. LEEANN SHANABROUGH SHERIFF'S RETURN OF SERVICE 04/05/2013 05:22 PM-DEPUTY HOLLY RODE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE(CIMF)BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE ERLYNE SCHNEIDER, MOTHER,WHO ACCEPTED AS"ADULT PERSON IN CHARGE"FOR LEEANN SHANABROUGH AT 345 NURSEY ROAD,WELLSVILLE, PA 17365. fgatfj,edtc HOLLY ROD , DEPUTY SHERIFF COST:$43.34 r"`'t• t4 u. , �,;i 5,2zr AS ACTING SHERIFF FOR April 11, 2013 RICHARD P KEUERLEBER, SHERIFF • NOTARY Affirmed and subscribed to before me this '' >> ��h 11TH day of APRIL 2013 / _ ( ( / l Boht in,i _ 447 Vh NOTARIAL COuntySuite Sheriff Te'aosof inc _ USA L TORPL,NOTARY;UBLIC A!i*V MP,VI4PYV 4lNIDU An,II Imo/ UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A.,as Trustee for Cumberland County the benefit of the Certiiicateholders of Popular ABS,Inc.Mortgage Pass-Through MORTGAGE FORECLOSURE Certificates Series 2004-5 Plaintiff NO. 13-858 Civil v. Leeann Shanabrough,Matthew P. Shanabrough Defendant(s) TO: Matthew P. Shanabrough 301 Cheryl Avenue Mechanicsburg,PA 17055 Date of Notice: June 11,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, 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 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 • NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TER ENO DE DIE?,(10)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA,CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN OFFICES, PC. BY: Attorney for Plaintiff ELIZABETH L WASSALL, PA ID 77788 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12040498 CASE#: 12040498-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A.,as Trustee for Cumberland County the benefit of the Certificateholders of Popular ABS,Inc.Mortgage Pass-Through MORTGAGE FORECLOSURE Certificates Series 2004-5 Plaintiff NO. 13-858 Civil v. Leeann Shanabrough,Matthew P. Shanabrough Defendant(s) TO: Leeann Shanabrough 345 Nursery Road Wellsville,PA 17365 Date of Notice: June 11,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,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 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DMZ,(10)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA,SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES,PC. BY: Attorney for Plaintiff ELIZABETH L WASSALL, ES WoodcresftAPp1170enter 111 Wooderest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12040498 CASE#: 12040498-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER MARK J. UDREN,ESQUIRE 111 WOODCREST ROAD SUITE 200 CHERRY HILL,NEW JERSEY 08003-3620 TINA MARIE RICH 856. 669.5400 OFFICE ADMINISTRATOR FAX:856. 669.5399 FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL Prothonotary of Cumberland County One Courthouse Square Carlisle,PA 17013 Re: The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank,N.A.,as Trustee for the benefit of the Certificateholders of Popular ABS,Inc.Mortgage Pass-Through Certificates Series 2004-5 vs. LEEANN SHANABROUGH,MATTHEW P. SHANABROUGH, Cumberland County C.C.P.No. 13-858 Civil MJU#: 12040498 CASE#: 12040498-1 Dear Sir or Madam: Enclosed please find Affidavit of Non-Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non-Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank , for your assistance in this matter. Sinc- ,o", Ale 1 , ' ar Fore losure Specialist MJU/ Enclosures MJU#: 12040498 CASE#: 12040498-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com The Bank of New York Mellon f/k/a The Bank COURT OF COMMON PLEAS of New York as successor trustee for JPMorgan CIVIL DIVISION Chase Bank,N.A.,as Trustee for the benefit of Cumberland County the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series MORTGAGE FORECLOSURE 2004-5 Plaintiff v. NO. 13-858 Civil LEEANN SHANABROUGH MATTHEW P.SHANABROUGH Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s),MATTHEW P. SHANABROUGH,who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s)is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether Defendant,LEEANN SHANABROUGH is in active military service because Plaintiff cannot provide date of birth and/or Social Security number for said Defendant, who is not a borrower on the loan,to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4 '!- relating to ':' orn falsification to authorities. garDated: 67P013 •ttorney f• Plaintiff • 1))'`�� # jW ; 110414t „ ROM Lc. } MJU#: 12040498 CASE#: 12040498-1 • Results as of:Jun-24-2013 09:48:13 Department of Defense Manpower Data Center SCRA 3.0 4i r Ya1f�. •- ., Status Report Pursuant to Servicemembets Civil Relief Act Last Name: SHANABROUGH First Name: MATTHEW Middle Name: P Active Duty Status As Of: Jun-24-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air 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. ,Yhttit YA.., )11011111641.. • 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 USC 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/PC09SLDR.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 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: N3BF7F64LODO1 D0 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.coin The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank, N.A., as Trustee Cumberland County for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through MORTGAGE FORECLOSURE ? Certificates Series 2004-5 Plaintiff c-- rat v. NO. 13-858 Civil , '- :. Leeann Shanabrough C Matthew P. Shanabrough = ' ' Defendant(s) c, PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 126,771.86 Interest From 6/26/2013 $ 3,439.26 to Date of Sale December 4,2013 Ongoing Per Diem of$21.23 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDRE► . " OFFI ',P QS?5°P1 a BY: aav . bO OF ' ��!'ey for Plaintiff °3. io rs s « Da vid Neeren, Esquire <, n MJU�: 12040498 CASE#: 12040498-1 PA ID 204252 $ _pp. SO pl or a5 CC. at_htscpaw i? / UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A., as Trustee Cumberland County for the benefit of the Certificateholders of c = Popular ABS, Inc. Mortgage Pass-Through MORTGAGE FORECLOSURE c Certificates Series 2004-5 7'0 rn Plaintiff cnr t v. NO. 13-858 Civil ,—I {7 T ;,y Leeann Shanabrough Matthew P. Shanabrough Defendant(s) CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: Z Act 91 procedures have been fulfilled Fl Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UD' -' •;.W.;004001-41, P.C. BY: Attorney or Plaintiff David Neeren, Esquire PA ID 204252 UaREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings(a,udren.com The Bank of New York Mellon f/k/a The Bank of COURT OF COMMON PLEAS New York as successor trustee for JPMorgan Chase CIVIL DIVISION Bank,N.A., as Trustee for the benefit of the Cumberland County Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series 2004-5 MORTGAGE FORECLOSURE Plaintiff v. Leeann Shanabrough NO. 13-858 Civil Matthew P. Shanabrough Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank,N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass- Through Certificates Series 2004-5, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 204-206 9th Street,New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Leeann Shanabrough 345 Nursery Road Wellsville, PA 17365 C-) Matthew P. Shanabrough - 301 Cheryl Avenue c_ Fri Mechanicsburg, PA 17055 r-- 2. Name and address of Defendant(s) in the judgment: C) } Leeann Shanabrough c-- 345 Nursery Road >- ' " ' Wellsville, PA 17365 Matthew P. Shanabrough 301 Cheryl Avenue Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank,N.A., as Trustee for the benefit of the Certificateholders of Popular ABS,Inc.Mortgage Pass- Through Certificates Series 2004-5 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders -None Citifinancial,Inc 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 204-206 9th Street New Cumberland, PA 17070 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: Federal Tax Lien Holders -None Condo/Homeowners Association- None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: G't $ I3 U! - • WO - P. BY: Atto ey for Plainti MJU#: 12040498 CASE#: 12040498-1 David Neeren, Esquire PA ID 204252 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATJ CENTER 111 WOODCREST ROAD, SUITE CHERRY HILL,NJ 08003-3620 856-669-5400 pleadiu sou mom The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York ps successor trustee for CIVIL DIVISION JPMorgan Chase Sank,N.A., as Trustee Cumberland County for the benefit of the Certificateholders of Popular ABS,Inc.Mortgage Pass-Through MORTGAGE FORECLOSURE Certificates Series 2004-5 R x Plaintiff V. NO 13-858 Civil w - LEEANN SHANABROUGH,MATTHEW F� P. SHANABROUGH Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew P. Shanabrough 301 Cheryl Avenue Mechanicsburg,PA 17055 Your house(real estate) at 204-206 9th Street,New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on December 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$126,771.86, obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call:(856)669-5400. 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 notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after 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 distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-858 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS SUCCESSOR TRUSTEE FOR JP MORGAN CHASE BANK,N.A.,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF POPULAR ABS,INC. MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-5 Plaintiff(s) From LEEANN SHANABROUGH,MATTHEW P.SHANABROUGH (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: $126,771.86 L.L.: $.50 Interest FROM 6/26/13 TO DATE OF SALE DECEMBER 4,2013-ONGOING PER DIEM OF $21.23 to actual date of sale including if sale is held at a later-$3,439,.26 Atty's Comm: Due Prothy: $2.25 Atty Paid: $388.50 Other Costs: Plaintiff Paid: Date: 7/1/13 `IN4 David D. Buell, thonotar (Seal) By: Deputy REQUESTING PARTY: Name: DAVID NEEREN,ESQUIRE Address: UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 204252 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings_@udren.com The Bank of New York Mellon f/k/a The Bank c' of New York as successor trustee for COURT OF COMMON PLEAS C CIVIL DIVISION —, JPMorgan Chase Bank,N.A. as Trustee for , the benefit of the Certificateholders of Popular Cumberland County P 1r, G ABS,Inc.Mortgage Pass-Through Certificates MORTGAGE FORECLOSURE Series 2004-5 LP j-r V. Plaintiff NO. 13-858 Civil �G �Q LEEANN SHANABROUGH, MATTHEW P. SHANABROUGH, -� Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff,by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as. Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt,which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit 'B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.sec.4904 relating to unsworn falsification to authorities. Dated: D r l J UDREN LAW OFFICES,P.C. Attorn for Plaintiff Nicole LaBlefla, Esquire MN#: 12040498 CASE#: 12040498-1 PA ID 202194 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A., as Trustee Cumberland County for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through MORTGAGE FORECLOSURE Certificates Series 2004-5 Plaintiff V. NO. 13-858 Civil Leeann Shanabrough Matthew P. Shanabrough Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank,N.A., as Trustee for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series 2004-5, Plaintiff in the above action,by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 204-206 9th Street,New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Leeann Shanabrough 345 Nursery Road Wellsville, PA 17365 Matthew P. Shanabrough 301 Cheryl Avenue Mechanicsburg, PA 17055 Matthew P. Shanabrough Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Leeann Shanabrough 345 Nursery Road Wellsville, PA 17365 Matthew P. Shanabrough 301 Cheryl Avenue Mechanicsburg, PA 17055 Matthew P. Shanabrough Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: i Commonwealth of PA, L&I to the use of the Unemployment Compensation Fund UI Payment Services, Fifth Floor,L&I Building Harrisburg, PA 17121 Commonwealth of PA,L&I to the use of the Unemployment Compensation Fund 1301 L&I Building, 6501 Boas Street Harrisburg, PA 17121 Commonwealth of PA, L&I to the use of the Unemployment Compensation Fund 10TH Floor, L&I Building Harrisburg, PA 19121 PA State Employees Credit Union 1 Credit Union Place Harrisburg, PA 17110-2912 PA State Employees Credit Union P.O. Box 67013 Harrisburg, PA 17106-7013 PA State Credit Union c/o Van Eck&Van Eck, PC P.O.Box 6662 Harrisburg, PA 17112 PA State Credit Union c/o Van Eck & Van Eck, PC 7810 Allentown Boulevard, Suite B Harrisburg,PA 17112 4. Name and address of the last recorded holder of every mortgage of record: The Bank of New York Mellon f/k/a The Bank of New York as successor trustee for JPMorgan Chase Bank,N.A., as Trustee for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series 2004-5 1661 Worthington Road-Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Citifinancial, Inc 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square j Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 204-206 9th Street New Cumberland, PA 17070 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: Federal Tax Lien Holders -None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: V'`, -l— L2 UDREN LAW OFFICES, P.C. BY: Attorney or P aintiff MJU#: 12040498 CASE#: 12040498-1 Nicole LaBlefla, Esquire PA ID 2 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08:003-3620 856-669-5400 The Bank of ew or eon a e COURT OF COMMON PLEAS Bank of New York as successor trustee for JPMorgan Chase Bank, N.A., as Trustee CIVIL DIVISION for the benefit of the Cerdficateholders of Cumberland County Popular ABS, Inc. Mortgage Pass-Through Certificates Series 2004-5 Plaintiff MORTGAGE FORECLOSURE V. LEEANN SHANABROUGH NO. 13-858 Civil MATTHEW P. SHANABROUGH; Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): LEEANN SHANABROUGH AND MATTHEW P. SHANABROUGH; PROPERTY: 204-206 9th Street,New Cumberland,PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/04/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which.will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 12040498 CASE#: 12040498-1 �c 00 --.l p w W = A c 0 0o Z y O. 00 0.0 A n e y.�� J N M N 00 , CD C CD 0 1 oc�o 9co 5p q Y � c �n p �, �-n w w a A O z �• C O:v < b N� ro w� �� a •s C C" eD �P y CD C co 0 0 N 7d O n �• o oNO R w 2. w " 0o0(A n 00 o° G o ^ < En O N c CD CD a m y iy fD C7 C) CD O B �T1 C. P• b � o w "`-CCCT a � � ❑❑�❑ r ° " CD C CI � °o°o�5' 1 - �f►'�hK/Fy1ul'lE+ O co tr O c w e-� _ � � � L �02.64 ❑❑ _ a ° � � . qrnw° ti w a o « 0711212013 CJ 'b tea , - � i a. o d i i' 16 Mailed From 08003 m m = US POSTAGE r � F n � �. e o cr CD CD m ❑ cp 0 010 n n Z d w " o fag rn o o 5'Oby�ie � l7 � e o8 � fR rn 5'0 3 o z CD n a CA �Q," CD W ^ N w ccm p C R U C oo n CD O ' w °Yw roam royw woo w~aoxCo 0 I n Z -s� CD cD '� H gr rnn, oco CGoF o�0° p � � m ��° roN$ b gw roe roo'� rov,~^�' CD � �o a aWO a apaa� tea- o a n i C•I ° ��[� C otz C*, eo D co qQ o Z ►.. PTI " 00 1--� R° f� cup rrz wN 00 n � I (. (D o . CD n CD ID n C CZ. o $' g D c ❑❑ ❑ C1 m°o°off o e ° ap6 �x spa °, �, � ❑` ❑"�'.� 7C' Py'0.�O � n. r• ^I t3 ro < 8 . C c c a �: y cr 0 5„ _ � U.S.POSTAGE*PtTr�BOwES o ff,9 9 c , �- W yrj' O o m 5 c n 90 CD 3. ZIP 08003 00 °_ . m�= 02 1 YV yb = . 0001387090 SEP.,r, d� x Sa: w o�apc M g = ° yob S e3 A o N x d rno rn�ro 0 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS' Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A., as Trustee Cumberland County for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series 2004-5 NO. 13-858 Civil Plaintiff V. LEEANNSHANABROUGH; MATTHEW P. SHANABROUGH; et al Defendants) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: UDREN LAW OFFICES,P.C. BY: AttorneyVor Plaintiff Nicole LaBlefta, Esquire PA ID 2 aQ 7/10/2013 10:57 AM FROM: Fax Civil Action Group, Ltd. TO: 17172446049 PAGE: 001 OF 002 Service of)Process by The Bank of New York Mellon,et al,PlahrtW(s) APS International, Ltd. LeLknn Shanabrough,et.al.,Ddrodam(s) 1-800-328-7171 APS INTERNATIOIML APS International Plata 7800 Glenroy Rd. Minneapolis,MN 55439-3122 APS File##: 12418L0001 AFFIDAVIT OF SERVICE --Individual Service of Process on: UDREN LAW OFFICES —LeeAnn Shanabrough Ms.Henni Crommarly Court Case No.Cumberland Co 13-858 Civil 1 l l Woodcrest Rd.,Ste.200 CherryHUl,NJ 08003-3620 - - - - - - —) - - - - - - — - - — - - — - - - - - - - - - - - - - - - - State of: ss. County of: Name of Server: j[. it 1J_L:e rl-SlI/r ,undersigned,being duly sworn,deposes and says that at the fune of service,s/he was of legal age and was not a party to this action; Date/Time of Service: that on the 4L day of 20 �,at -O�o'clock M Place of Service: at 345 Nursery Road ,in Wellaft PA 17365 Documents Served: the undersigned served the documents described as: Notice of Sherffrs Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s)was served on: LeeAnn Shanabrough Person Served,and Method of Service: El By personally delivering them into the hands of the person to be served. By delivering them into the hands of_f/* t 4:11 t2g.1>��f,a person of suitable age,who verified, or who upon questioning stated tha he/shetresid with LeeAnn Shanabrough at the place of service,and whose relationshi the person is: a f �, Description of Person The person receiving documents is'described as follows: Receiving Documents: Sex_l"_; Skin Color 4//k-7 Hair Color �' k 7 Facial Hair n6 LIE Approx.Age 2 2? Approx. Height r_S 10 Approx. Weight ❑ To the best of my knowledge and belief,said person was not engaged in the US Military at the time of service. Signature of Server. Undersigned declares under penalty of perjury Subscn' Fd ands before me this that the foregoing is true and correct. p'�p� day of ,20 I� A C2 Ad Signature of Server Notary blic (Commission ires APS International,Ltd. NOTARIAL SEAL JAYNE L ENGLAND Notary Public WEST MANCHESTER TWP.,YORK COUNTY My Commission Expires Dec 17.2013 a �oaa� Q Oct- 18. 2013 11 :42AM Cumberland County Sherrif No, 7807 P. 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff CoN�a��R o!Cure6rt11�b Jody S Smith Chief Deputy M. Richard W Stewart Solicitor OFFICE OF THE SHERIFF The Bank of New York Mellon,f/kla The Bank of New York Case Number I vs. Leeann Shanabrough(et al.) 2013-858 SHERIFF'S RETURN OF SERVICE 09/97/2013 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: Leeann Shanabrough,but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ,Notice and Description, in the above titled action,according to law. 09/20/2013 09:40 PM-Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action,by making known its Contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Shanabrough at 1101 Claremont Rd, CCP, Carlisle, PA 17013, Cumberland County. 09/23/2013 08:28 PM-Deputy Stephen Bender, being duly sworn according to law,states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 204.209 9th Street, New Cumberland-Borough, New Cumberland, PA 17070, Cumberland County, SHERIFF COST:$1,150.70 SO ANSWERS, October 18,2013 RbNW R ANDERSON, SHERIFF (c)00Qmg3Ldie Shenk,Teleosoft,Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York as successor trustee for CIVIL DIVISION JPMorgan Chase Bank,N.A., as Trustee Cumberland County for the benefit of the Certificateholders of Popular ABS,Inc. Mortgage Pass-Through Certificates Series 2004-5 NO. 13-858 Civil Plaintiff V. LEEANNSHANABROUGH; MATTHEW P. SHANABROUGH; et al Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: l UDREN LAW OFFICES, P.C. BY: Attorney or Plaintiff Nicole LaBlefla, Esquire PA ID 2 C) - :MM -<> =q 7/10/2013 10:57 AM FROM: Fax Civil Action Group, Ltd. TO: 17172448049 PAGE: 001 OF 002 Service of Process by The Bank of New York Mellon,et.al.,Ptaiutitf(s) APS International, Ltd. VS. LeeAnn Shanabrougb,et.al.,Defendanks) 1-800-328-7171 APS INT(;BNA.T1ONAr, APS International Plaza 7800 Glenroy Rd. Minneapolis,MN 55439-3122 APS File#: 124182-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: UDREN LAW OFFICES -LeeAnn Shanabrough Ms.Henni Crommarty Court Case No.Cumberland Co 13-858 Civil 111 Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 State of- - - - l- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - County of: /� 0 r k ) c Name of Server: Roo AD r j ,undersigned,being duly sworn,deposes and says that at the ime of service,s/he was of legal age and was not a party to this action; Date/Time of Service: that on the day of �./� ,20 ,at afo'clock FM Place of Service: at 345NurseryRoad in Wellsville.PA 17365 Documents Served: the undersigned served the documents described as. Notice of Sheriff's Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s)was served on: LeeAnn Shanabrough Person Served,and Method a Service: El By personally delivering them into the hands of the person to be served.Ik By delivering them into the hands of 9-./' y MG sC 17 Ct EJ 042e ,a person of suitable age,who verified, or who upon questioning stated tha he/8 tresid with LeeAnn Shanabrough at the place of service,and whose relationshi the person is: In a Description of Person The person receiving documents is'described as follows: Receiving Documents: Sex ,Al ; Skin Color 4/4- 1 ; Hair Color L; Facial Hair f� Approx. Age 'J:� Approx. Height c I Q Approx. Weight ❑ To the best of my knowledge and belief,said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury Subscn'l d and sw M to before me this that the foo7regoing..is true and correct. as day of ,2013 'Signature of Server Notary blic (Commission ires APS International,Ltd. NOTARIAL SEAL JAYNE L ENGLAND Notary Public FWEST MANCHESTER TWP.,YORK COUNTY Comm ission Expires Dec 17.2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f J t` Sheriff t } t:i Jody S Smith Chief Deputy �.v �t ✓tit *�� Richard W Stewart n Solicitor OFFICE OF THE 4WERIFF Pi~�iNS�,�tU i���tt`'�'i, f`✓ L VA The Bank of New York Mellon, f/k/a The Bank of New York Case Number vs. Leeann Shanabrough (et al.) 2013-858 SHERIFF'S RETURN OF SERVICE 09/17/2013 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: Leeann Shanabrough, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 09/20/2013 09:40 PM -Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Shanabrough at 1101 Claremont Rd, CCP, Carlisle, PA 17013, Cumberland County. 09/23/2013 08:28 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 204-209 9th Street, New Cumberland -Borough, New Cumberland, PA 17070, Cumberland County. 10/22/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of York County upon LeeAnn Shanabrough, personally, at 345 Nursery Road, Wellsville, PA 17365 on 9/23/13 at 1701 hrs . So Answers: Michael Donovan, Deputy, Sheriff. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of The Bank of New York Mellon, f/k/a The Bank of New York as sucessor trustee for JPMorgan Chase Bank, N.A., as Trustee for the benefit of the Certificateholders of Popular ABS, Inc., Mortgage Pass-Through Certificates Series 2004-5, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,190.48 SO ANSWERS, January 10, 2014 RbNtV R ANDERSON, SHERIFF of D� P� a4 .2 •a5 ,,(. Co• 3Oo X97 (c)CountySuite Sheriff,Teleosoft,Inc. Y On September 17, 2013 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Known and numbered as, 204-206 9th Street, New Cumberland, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: September 17, 2013 By: Real Estate Coordinator ,q0 :01 a Z- ;elf E131 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-858 Civil Term 204-206 Ninth Street.New Cumber- land,Pennsylvania. THE BANK OF BEING KNOWN AS: 204-206 9th NEW YORK MELLON Street, New Cumberland, PA 17070 VS. Property ID No.:26-24-08-281A. LEEANN SHANABROUGH, TITLE TO SAID PREMISES IS Matthew Shanabrough VESTED IN Matthew P.Shanabrough by deed from Matthew P.Shanabrough Atty.: Mark Udren and Leeann Shanabrough,husband ALL THAT CERTAIN tract or par- and wife dated 02/17/2006 recorded cel of land and premises, situate, 03/13/2006 in Deed Book 273 Page lying and being in the Borough of 2645. New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania and described accord- ing to a map of property made by Gerrit J. Betz, Registered Surveyor, dated April 19, 1972 as follows: BEGINNING at a hub on the southerly side of Ninth Street(50 feet wide),at a corner of Lot No. 157,said point of beginning being measured along the said side of Ninth Street in a southerly direction a distance of one hundred forty-seven (147) feet from its point of intersection with the side of Market Street;thence extend- ing from said point of beginning and along Lot No. 157,South 27 degrees 30 minutes East, the distance of one hundred thirteen (113) feet to a hub on the northerly side of a ten (10) foot wide alley; thence extend- ing along the said side of said alley, South 62 degrees 30 minutes West, a distance of seventy-four (74) feet to a hub at a corner of Lot No. 160; thence extending along Lot No. 160, North 27 degrees 30 minutes West, a distance of one hundred thirteen (113) feet to a hub on the southerly side of Ninth Street;thence extending along the said side of Ninth Street North 62 degrees 30 minutes East, a distance of seventy-four(74)feet to the first mentioned point and place of BEGINNING. BEING SHOWN AS Lot Nos. 158 and 159 on the Plan of Lots of Elk- wood, recorded in Plan Book M-5, Page 498. HAVING THEREON ERECTED a dwelling known and numbered as 107 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. (-)Lisa Marie Coyne)Editor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 wo Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. ° 2120 Technology PkWy the r10 e s Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is 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. PUBLICATION COPY This ad ran on the date(s)shown below: 10/13/13 R` 2013.856 Chill Tenn 10/20/13 HE BANK OF NEW YORK i ^ 10/27/13 MELLON L EANN SHANABROUGH Matthew Shanabrough ALL THAT CERTAIN den PARCEL OF LAM OR Sworn to and subscribed before met 11 day f November, 2013 A.D. SITUATE, F LA D AND PREMISES, y BOROUGH OF NEW BEING IN THE IN THE CO CUMBERLAND AND COUNTY OF CUMBERLAND PENNSYLVANIA COMMONWEALTH OF ACCORDING AND DESCRIBED T PROPERTY MADE BY GERR�B%Z REGISTERED SURVEYOR DATED COMMONWEALi ri OF P SYLVANIA APRIL 19,1972 AS FOLLOWS: Notarial Seal BEGINNING AT A HUB ON THE Holly Lynn Warfel,Notary Public SOUTHERLY SIDE OF NINTH Washington Twp.,Dauphin County STREET (5o FEET WIDE), AT A My commission Expires Dec.12,2016 CORNER OF LOT NO. 157, SAID MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES POINT OF BZRLh N BEING MEASURED ALONG THE SAD SIDE OF NINTH STREET IN A SOUTHERLY _ _DIRECTION A DISTANCE OF ONE , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 1, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of New York Mellon as sucessor Trustee for JP Morgan Chase Bank,NA as Trustee for the benefit of the Certificateholders of Popular ABS Inc, Mortgage Pass-Through Certificate Series 2004-5 is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 1 st day of Jam,A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 858, at the suit of Bank of New York Mellon as sucessor Trustee for JP Morizan Chase Bank,NA as Trustee for the benefit of the Certificateholders of Popular ABS, Inc., Mortgage Pass-Through Certificates Series 2004- 5 against Leeann Shanabrough and Matthew P. Shanabrouih is duly recorded as Instrument Number 201401153. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 15- day of ,�!2 0 , A.D. a0I Recorder of deeds Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018