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HomeMy WebLinkAbout13-0950KML LAW GROUP, P.C. ~: ~~ t~~, r~~ , a ,,.:: SUITE 5000 - BNY MELLON INDEPENDENCE CENTER,,., t- < ~ : ~' 1 <3 T ~ ~~~~ `~ ~ti , 701 MARKET STREET '° ~ ~ ~ ~ (866) 413 2311 ~ PA 191.06 ,~ ~ ~ ~ ~ ~ ~ ~ ~~ ~~; I v 3 JPMORGAN CHASE BANK, NATIONAL vL"l~Il~ ASSOCIATION, SUCCESSOR IN INTEREST BY ~ ~~ PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK, FA c/o 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. "~""' ~ - - THE COURT OF COMMON PLEAS ~Y~.VAN1~ OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE JAMES L. MILLER STEPHANIE L. MILLER Mortgagor(s) and Record Owner(s) 296 Old Stone House Road Carlisle, PA 17013 Defendant(s) 2 (~ C(,~Vl I No. ~ J' L~D CIVIL ACTION: MORTGAGE ~~~ NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones~ de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. ~~ 7 aq~ 3 ~ 7 ~~ a~~~~ ~ LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES 1NC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. l ). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.or~/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 102723FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK, FA, c/o 3415 Vision Drive, Colombus, OH 43219. 2. The name(s) and address(es) of the Defendant(s) is/are JAMES L. MILLER, 296 Old Stonehouse Road, Carlisle, PA 17013 and STEPHANIE L. MILLER, 296 Old Stonehouse Road, Carlisle, PA 17013, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 25, 2002 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK, FA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on January 31, 2002 as Book 1747 Page 4199. The mortgage has been assigned to: WASHINGTON MUTUAL BANK by assignment of Mortgage recorded on August 07, 2006 as Book 729 Page 1918. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June O 1, 2010 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of January 31, 2013: Principal Balance .......................................................... Interest from 05/01/2010 through 01/31/2013 ........... Accrued Late Charges ................... $296,442.21. .................................................................. Escrow Advance .......................................................................... BPO/Appraisal ............................................................................. Property Inspection ...................................................................... Reasonable Attorney's Fee .......................................................... ............... $49, 03 6.4 7 .................... $191.19 ...............$11,556.96 ......................$95.00 .................... $ 3 62.25 .................$1.300.00 $358,984.08 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiffhas no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiffdemands a de terns judgment in mortgage foreclosure in the sum of $358,984.08, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. ~7 By: KML LAW OUP, P.C. Michael McKeever Pa. ID 561.29 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 /Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Pennsylvania Verification Stephanie Blouin ,hereby states that h she is Vice President of JPMor~an Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Stephanie Blouin Vice President Date: 02/02/13 JPMor~an Chase Bank, N.A Borrower: James L. Miller and Stephanie L. Miller Property Address: 296 Old Stone House Road, Carlisle, PA. 17013 County: Cumberland Last Four of Loan Number: 6795 E~kiditA ALL THAT CERTAIN. tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, being identified as Lot 9 as shown on a plan of lots known as Pheasant Crossing prepared for Realand; Inc., by Hoover Engineering Services, Inc., dated August 10, 1998, approved October 7, 1998 by the Middlesex Township Board of Supervisors, ar~d recorded November 6, 1998 in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77, page 128, and being more fully described as follows, to wit: BEGINNING at a point in the centerline of T-591 {Old Stone House Road); thence by Lot 8 of the aforementioned subdivision South thirty-seven (37) degrees fifty-three (S3) nunutes six (06) seconds West a distance of five hundred twenty-four and ninety-fivo hundredths (524.95) feet to an iron pin; thence by Lot 8 and by Lot 7 of the afozr~mcntioned subdivision South fifty-two (52) degrees au (06) minutes fifty-fora (54) seconds East a distance of three hundred fifty (350.00) feet to an iron pin; thence by Lot 6 of the aforememioned subdivision South thirty-seven (37) degrees fifty-three (53) minutes six (06) seconds West a distance of sue hundred ninety-one and fifty-nine hundredths (69 ] .59) feet to an iron pin; thence liy Lot 11 of the aforementioned subdivision South eighty-eight (88) degrees fifteen . (15) minutes zero (00) seconds West a distance of one hundred twenty-seven and eighteen hundredths (127.18) feet to an Trott pin; thence by land now or formerly of Robert Line and J. Edward Clouse North one (Ol) degrees forty-five (45) minutes zero (00} seconds West a distance of seven hundred seventeen and twenty-three hundredths (717.23) feet to an iron pin; thence by I.ot 10 of the aforementioned subdivision. North tighty-eight (88) degrees fifteen (15) minutes zero (00) seaands East a distance of two hundred sixty and thirty hundredths {260.30) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North thirty-seven (37) degrees fifty-three (53) minutes six (06) seconds East a distance of five hundred twenty-four and ninety-eight hundredths (524.98) feet m a point in the centerline of T-S91; thence in along and through the centerlue of T•591 South fifty-two (52) degroes five (05) minutes twenty-four (24) seconds East a distance of fifty (50.00} feet to a paint in the centerline of T-591 (Old Stone House Road) the place of BEGINNING. CONTA1lVING 7.2$1 acres of land as surveyed. BEING the same premises which Realand, Inc., a Pennsylvania corporation, by Deed bearing date of the 1st day of the October 1999, and recorded on rho 18th day of November, 1999 in the Office of the Recorder of Deeds in and for G~trnberland County, Petmsylvania, in Deed 23oak 21 ],Page 793 granted and conveyed unto James L. Miller and Stephattie L. Miller, husband and wife. LJN]]ER ANb SUBJECT TO restrictions and conditions as now appeaz of record. Tax Map #ZI-08-OS73-133 ~E.,~Fii6it ~ *Exhibit has been redacted to remove all personally identiftable information or non public information Chase Home Finance LLC FLS-7730 PO BOX 44090 Jacksonville, FL 32231-4090 July 6, 2010 STEPHANIE L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 028541 CHASE NOTICE OF COLLECTION ACTIVTI'Y RE: ACCOUNT # _6795 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSL:IRE This is an official notice that the mortgage 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 rra¢es The HOMEOWNER'S EMERGENCY MORTGAGE A ISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the program works To see if HEMAP can help. you mu t MEET WITH A CONSUMER REDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of thu Notice. If you have anv questions you may call the Pennsylvania Housing Finance Agency toll free at 1 800-342 2397 (Persons with impaired hearing can call X717 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 ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. C0826 Chase Home Finance LLC FLS-7730 PO BOX 44090 Jacksonville, FL 32231-4090 July 6, 2010 JAMES L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 028540 CHASE NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # _6795 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intend to foreclose Specific information about the nature of the default is urovided in the attached pees The HOMEOWNER'S EMERGENCY 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 Agency The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (7171 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 ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. cosz6 HOMEOWNER'S NAME(S): James L. Miller PROPERTY ADDRESS: 296 Old Stone House Rd Carlisle PA 17013 LOAN ACCT. NUMBER: _6795 ORIGINAL LENDER: CURRENT LENDERlSERVICER: Chase Home Finance LLC 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 BY 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. TH MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YO 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 CREDTI' COUNSELING 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. The names. addresses. and telephone numbers of designated consumer credit counseling agencies 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). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. 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 stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 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 APPLICATTON EVEN BEYOND THESE TTME 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 (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION 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.) 0285x0/CO826 HOW TO CURE YOUR MORTGAGE DEFAULT fBring_it up to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 296 Old Stone House Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 06/01/2010 $1937.04 07/01/2010 $1937.04 Other charges (explain/itemize): Uncollected Late Charges $30.00 Uncollected Fees: $0.00 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $3904.08 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): 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 $3904.08, 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- Chase Home Finance LLC Attn: OH4-7133 3415 Vision Drive Columbus, OH 43219 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE DEFAULT - If you do 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 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 reasonable 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 cure the default within the THIRTY f30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES -The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 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 a~ the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortea~e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Toll Free: Contact Person: Email Address: Chase Home Finance LLC Mail Code FLS-7317 PO Box 41275 Jacksonville, FL 32203-1275 (904) 886-1308 (800) 848-9380 Kimberly Smith kimberly.brown@chase.com EFFECTS 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 or JL may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING 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 ARE ATTACHED An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Chase offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 1-800-848-9380 to discuss your options. The longer you delay the fewer options you may have. WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. C0826 ~hi6it C *Exhibit has been redacted to remove all personally identifiable information or non public information Return to: Shapiro and Kreisman, LLC 2520 Renaissance Blvd, Suite l 50 ICixig of Prussia, PA 19406 6ia.2~s-aeon - Parcel JD#; 21-08-0573-133 ~~' ~ •..P ~CG6 Pur; 7 t~t~ 11 `t7 7HE 1180VE SPADE FdR l~CfillpNrQ lIt3E QNLY 06-26678 ~i795 ASSIGIITMENr OF MORTGAGE Maatgage Electronic Registration Systews, Inc., as nominee 1'ar Washington Mutual Bank, FA (Assigrwr), for and in oonsidaration of the snrn ~of Ten Dollars (S 10.00) and other good and vahrable consideration, the receipt of which is acdmowledged, dots g~ bargain, sell, assign cod traumfer to Washington Mutual Back (Assignee), a corporation with an office located at 1270 North~tmd Drive, Suite 200, Mendota Heights, Mn 55120 and authorized to do business at that addross, all of its right, title and interest, as holder o~ in, end to the fiollowing described mortgage, the ptoprxty described and the ~ sccsmd by the mortgage: ORII~IAL MORTdA(30R(S): James L. Miller and Stephanie L. Miller OR1d1INAJ.MORTdAGEE: Mortgage Electronic Registration Systems, Inc., as nominoe for Washimgto® Mutual Bank, FA DATE )~CECUTED: January 25, 2002 AMOUNT S»G[.TRF.D: 275,500 DATE RECORDfiD: January 3l, 2002 BOOK t 747 PAGE: a t 99 Recorded in Curnberlend t;ouuoty, CommortroNeakbi ofPetmsylvania (Mortgage ). Soe Attached Legal Description Pmnanv Addraa: 296 Old Shane pause Road, Carlisle,l?A 17013 TogFthar with the note or obligation described in the Mortgage endorsed to tlu Assignee, ("Nc6e'~ and all aroneys due and to bocoroe due ~ the rote cad Mortgage, with ia~est Assignee ib suaceseors, le®el t+epives and aaaigas shall hold all rights undue the Note and Mottga®e tlxever, subject however, in the right sad equity of redemption, if any, of the malmc(s) of the Mortgage, their heirs and assigns forever. EFFECTIIVE DATE: May 19, 2806 Assignor, by its ~te corporates otEcers, has executed and sealed with its corporate seal this Assignment of Mortgage on this ?~_ day of rt ll L'~ ,2006. (Affnc Corporate Seel) ~''t~~29~~9i8 ~ ~ ~~~~~~e~ ~~ b ~~~~ ~y~^~ ~~~~ ~~~}~~R~(~~ ~~~~e~gE a~~' ~~~~i ~~ ~~~~a~~~~~{~ ~~ ~ ~~~~ 3~~1~~~ ~~,~~j~.n ~ ~ ~ ~~ ~ ~~~~~' ~~~a~~~j~~~ ~; ~ ~y~~ ~ i ~~~~~~~~~7t¢~ti3 ~ie~~ ~ ~~~~ ,i b,~~~ ~ ~ ~ ~~~s ~ ~~ a ~~~~~~ ~#~~~~ i~~ ~ ~~ ~ ~ay~~~~~~s~~~~ ~~~~ ~ ~~.~b~ ad~E~ ~~~ N ca r ~ s ATTEST: Mottgag El ~ n Systems, Inc., as m Mutual Bank, FA Name: ~ -tr~4ik ~ C K Title: ~~~~ Titlo: ~~ Pf~~ STATE OF t!~ COUNTY OF 7a1- ) BE Fl REiNtEllriBl3RED, that ore this 1l~% day of ~1Lt ,2006, before mc. fho subuxiber, a Notary Public pereonelly appa~red ('etc ~p,~rsst? end ~.Y+~-~I- .~1:~ o~oas of Assignor, vvho I enn satisfied ere the persona who si~ the withia insonutaerkt and they aclaaovvladth~ they Si9~ed. sealed with the corporate stet and deliverod the saw a6 such officeaa atSo~d, and that the within instnnnent is the votuntacy act and deed of such oorporatian made by virtue of a Resolution ofits Board of Directors. tiltTr~ a. ~sorv taomrtrrtle~tc-rat "'~ ~ ~..-7~~ MY Ct7MMl45! GN EXPIRES JAN. 31,2010 Notary Public My comrrrission txpi[ts: ~ ~~• 1 hereby oortify that the correct address of the ASSt(3N1:?E is: 1270 Northland Dr., Spite 200 Mendota Heights, Minnesota 55120 Alexis Conne]Iy '" Our File No: 06-26678 C(ient No: 8459546795 Please m: First Financial Absfxact Comg~any of Peanaylvauia, znc. 2320 Renaisaeucc Blvd. king of Prvasia Tel; (610) 278-6800 Fax: (610) 278-9980 I Certify this t0 be retarded In Curnber~and County FA M ~t~ ~~" ~'. ~:=order of,Deeds ~t Q.7 2 gP6 i g~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA~iIA - ...-- Sa~.a r ~» ~~~ JPMORGAN CIIASE BANK, NATIONAL ASSOCIATION, ~ SUCCF,SSOR IN INTEREST BY PURCHASE FROM THE a1 "~~ ~, FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK ~ 3~ I J -C Case No. F/K/A WASHINGTON MUTUAL BANK, FA 4~ ~ ~ ~ 7~" Plaintiff ~ ~' ~'` .~.- ~ c vs. ~ ~ ~ i JAMES L. MILLER ~`` STEPHANIE L. MILLER Defendant(s) r:`* ~~ ~~,~ .»:j -.rz°t y ~~ ~-} c: ~ .,.-is~ r ~n Vy ~ .~_ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. 1f you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: l/~- Z-, ~ (Signature of ounsel for Plaintiff) 2/18/2013 Date Cumberland County Residential Mortgage Foreclosure DiveXSion I'rograxa )H'inancial. Worksheet Date _ Cumberland County Court of Common Pleas bocket BORROWER REQLrES"f >~OR HARDSHIP ASSISTANCE 'To complete•your request for hardship assistance, your leader must consider your circunnstances to determine possible options while working with your Please provide the folbwing information to the best of your knowledge: Borrower names}: Property Address: City: ___ - State: .Zip: Is the property for sale? Yes ^ No ^ Lstsng date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): ~~~ City: State: Zip: Phone Numbers: Home: QBiee: Cell: Qther: Email: _ # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: _ __ Email: # ofpeople in household: How long? First Mortgage Lender: Type of I1oan; Loan Nurrtber: Date You Closed Your t.,oan: Second Mortgage Lender: Type of Loan: Loan Nurnbcr: • Total Mortgage Payments Amount: $ Date of Last Payment: Included Faxes & Insurance;_______ l'rim~ Reason far default: Is the loan in Bankruptcy? Yes ^ No [] if yes, provide names, location of court, case number & attorney: Assets Hoene; Other Real Estate: Retiremenk Funds: lnvestrnents: Checking: Savings: Other: Amount Owed: $_ $_ Value:_ __ Automobile #I: Model: Year:. Amount owed: ~ Value: T Automobile #2: Model: Year: Amount owed: Value: ___~____.. Outer transportation (automobiles, boats. motorcycles~ Model: Year: Amount awed: Value _ _ _ _ Month Income Nartte ol= Employers: l . ~. 3. Additional Income Description (not wages}: l . monthly amount: 2 ~ monthly amount: Borrower Pay Days:, Co-$arrawer Pay Days: Monthly Expenses: (Please only include expenses you are currently paying} EXPENSE AMO[JNT EXPENSE AM©LTN1' Mo a Food 2 M Utilities Car Pa bn s Condo/Nei .Fees Auto Insurance Med. not coverall Auto fuel/re irs Other ro a meat Install. Loan Pa mcnt Cable TV Child Su rtlAlim. S din Move DayiChild Care/Tuit. 4tlter Ex nses Amount Available far Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? 'Y'es (~ No If yes, please provide the following information: Counseling Agency: Cauciselar: Pbone (Office):. 1~ax:T email: Have you made application for Homeowners 1/mergency 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 ar leader's Loan servicing company: T.,ender's Contact {Name): Servicing Company (Name): Contact: Phone: Phone: Y/~t'e, ,authorize thz above named to usefrefer this information to my lender/scrvicer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that Uwe amlare under no obligation to use the services provided by the above named Bonnwer Signature Date Co-Borrower Signature Date please forward this document along with the following information to lender and lend-e!r's counsel: Proof of income ~-Vr isast 2 bank statements Y Proof of any expected income for the last ~5 days Copy at a current utility bill Letter e~cplaiining reason for delinquency and any supporting documentation ' + (hardship letter} V Listing agrecmet~t (if property is Curren#iy on tl~e market) In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA No. 13 950 Civil c/o 3415 Vision Drive Columbus, OH 43219 c ' C7 C= Y Plaintiff C-- -t vs. M3 W G JAMES L.MILLER Z -p 1i STEPHANIE L.MILLER r— cj (Mortgagor(s)and Record Owner(s)) C=' `J i :, 296 Old Stone House Road Carlisle,PA 17013 % 1 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against JAMES L.MILLER and STEPHANIE L.MILLER by default for want of an Answer. Assess damages as follows: $358,984.08 Debt Interest from 2/1/2013 to Date of Sale per diem at$36.55 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or de 'vered to the party against whom judgment is to be entered and to his attorney of record,if any,after the defa cc ed at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.23 By. p l� n-rrY KM CL ,P.C. I b•5� Michael cKeever Pa.ID 56129 �3q 5'17 Jay E.Kivitz Pa.ID 26769 //__ Lisa Lee Pa.ID 78020 �#I l�y g b Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 t ;C� mot.I led Thomas Puleo Pa.ID 27615 N „ Joshua I.Goldman Pa.205047 Jill P_Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Attorneys for Plaintiff AND NOW '`]t 1' June ab13 ,Judgment is entered in favor of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHIN TON MUTUAL BANK,FA and ag ' t JAMES L.MILLER and STEPHANIE L.MILLER by default for want of an Ans er ando g IN ssed in the s f $358,984.08 as per the above certification. P 102723FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DFBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DNFE OF THIS NOTICE: May 29,2013 TO: JAMES L.MILLER 296 Old Stonehouse Road Carlisle,PA 17013 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST Common Pleas BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK of Cumberland County r-WA WASHINGTON MUTUAJ,BANK,FA c/o 3415 Vision Drive CIVIL ACTION-LAW Colomhus,0II43219Plainti VS. Action of JAMES L.MJJLFR Mortgage Foreclosure STEPHANIE L.MILLER No.13 950 Civil (Mortgagor(s)and Rea)rd O%ner(s)) 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) TO: JAMES L.MILLER 296 Old Stonehouse Road Carlisle,PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAKED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TILE COURT YOUR DEFENSES OR OBIECTIONS'1'O THE CLAIMS SET'FORTII AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOST:YOUR PROPERTY OR OTHER DAPORTANT RIGHTS. YOU SHOUID TAKE THIS PAPER TO YOUR LAW YF.R AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR'11;I.FPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE.CAN PROVIDE YOU WITII INFORMATION ABO[1T 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 ELIGIBI_E PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvin Row Carlisle,PA 17013 717-243-9400 By: - KMI: AW GR UP,P.C. Michael McKeever Pa.ID 56129 --Lisa Lee Pa.ID 78020 `Krishna-Murtha Pa.11161858 _]David Fein Pa.ID 82628 1 mas Puled Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Otlazian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff 102723FC THIS LAW FIRM IS A DEBT COLLECTOR AND W E ARE ATTEMPTING TO COLLECT A DEBT ONVED TO OUR CLIF.NT.ANY INFORMA'T'ION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING TITE DEBT. DATE OF THN NOTICE: May 29,2013 TO: STEPHANIE L.MILLER 296 Old Stonchouse Road Carlisle,PA 17013 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCFSSOR IN INTEREST Common Pleas BY PURCHASE FROM THE FIXC AS RECEIVER OF WASHINGTON MUTUAL BANK of Cumberland County F/K/A WASHINGTON MUTUAL BANK,FA c/o 3415 Vision Drive CIVIL ACTION-LAW Colombus,OH 43219PIainiiff Vs. Action of JAMES V.MILER Mortgage Forecknure STEPHANIE L.MILLER Na. 13 950 Civil (Mortgagor(s)and Record Owner(s)) 296 Old Stone House Road Carlisle,PA 17013 Defendani(s) '1'0: STEPHANIE I—MILLER 296 Old Stonehouse Road Carlisle,PA 17013 IMPORTANT NOTTCE YOU ARE IN DEFAULT BF:CAi1SE YOU HAVE FAILYD TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRIITNG WTTIi THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)DAYS FROM THE DATE OF THIS NO'fICh,A JUDGMENT MAY BE=ENTERED AGAINST YOU WITHOUT A IIEARING AND YOU MAY LOST YOUR PROPERTY OR OTHER IIvIPORTANf RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE_ IF YOU DO NOl'RAVE 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 I AWYER,THIS OFFICE MAY BE ARI3?TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL S FR VICES TO ELIGIBlY.PFRSONS AT A REDUCED FEE OR NO FEE. CUMBERI.AND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By ALAW UP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristine Murtha Pa.ID 61858 _David Fein Pa.ID 82628 /homas Puleo Pa_ID 27615 Jill P..Icnkins Pa.ID 306588 Alyk L.011azian Pa.ID 31291.2 215-6274322 Attorneys for Plaintiff 102723FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL.BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: May 29,2013 JAMES L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST Common Pleas BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK of Cumberland County FIK/A WASHINGTON MUTUAL BANK,FA c/o 3415 Vision Drive CIVIL ACTION-LAW Colombus,OH 43219 Plaintiff vs. Action of JAMES L.MILLER Mortgage Foreclosure STEPHANIE L_MILLER (Mortgagor(s)and Record Owner(s)) No. 13 950 Civil 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) TO: JAMES L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 Il ff ORTANT 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 s T FORTH AGAINST YOU. UNLESS YOU ACr WrTHIN TEN (10)DAYS FROM THE DATE.OF TIES NOTICE,A JUDGMENT MAY BE ENFERED AGAINST YOU WTTIIOUT A III ARING 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. ITIIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER.LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvin Row Carlisle,PA 17013 717-243-9400 By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 __ Kristina Murtha Pa.ID 61858 ^David Fein Pa.ID 82628 Trmas Pulco Pa,ID 2761 P Jenkins Pa_11)306588 k 1..011azian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff 102723FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEIVWFING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING TILE DEBT. DATE OF THIS NOTICE: May 29,2013 TO: STEPHANIE L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST Common Pleas BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK of Cumberland County FWA WASI IINGTON MUTUAL BANK,FA c/o 3415 Vision Drive CIVIL ACTION-LAW Colombus,OH 43219 Plaintiff vs. Action of JAMES L.MILLER Mortgage Foreclosurc STEPHANIE L.MILLER No.13 950 Civil (Mortgagor(s)and Record Owner(s)) 296 Old Stone House Road Carlisle,PA 17013 Defendant(v) TO: STEPHANIE L.MILLER 296 Old Stonchouse Road Carlisle,PA 17015 rMPORTAN'1'NO'T'ICE 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. IJNLESS YOU ACT WVITH J TEN (10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 0THER IMPORTANT RIGHTS. YOU SHOULD TAKE TIES 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 II RE A LAWYER,THIS OFFICE MAY BE ABLE,TO PROVIDE..YOU Wr1'H INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE-OR NO FE•E. CUMBERLAND COUNTY BAR ASSOCIA7110N 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: _ KML LAW C.R16UP,P.C. Michael McKeever Pa.H)56129 Lisa Lee Pa.ID 78020 Krishna Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Pulco Pa_/1127615 �Aill P.-Jenkins Pa_ID 306588 iyk L.OOazian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA Plaintiff NO. 13 950 Civil vs. JAMES L.MILLER STEPHANIE L.MILLER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): JAMES L. MILLER, has a last known residence of 296 Old Stonehouse Road, Carlisle, PA 17015. The following information was used to search the DMDC (check all that apply): Last Name X First Name _X_Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 49)4 r lating to unsworn falsification to utl riti s. Date By: KML LA Michael eeve a. ID 56129 Lisa Lee Pa. 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua 1. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 'NkJill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa. ID 312912 Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Stilr 05a�arJGrrf�f1� Jody S Smith ; Chief Deputyt Richard W Stewart Solicitor O:IcEOF TI-E. k=FjPC JP Morgan Chase Bank, National Association, Successor in Interest by P Case Number vs. 2013-950 James L Miller(et al.) SHERIFF'S RETURN OF SERVICE 02!25/2013 06:48 PM-Deputy Shawn Harrison, being duly sworn according to law,served requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing the el es to be James Miller, husband of defendant,who accepted as"Adult Person in Charge"for Wae iller at 296 N.Old Stone House Road,Middlesex Township,Carlisle, PA 17015. S ON, DEPUTY 02!2512013 06:48 PM-Deputy Shawn Harrison,being duly sworn according to law,sery h requested Complaint in Mortgage Foreclosure by"personally"handing a true copy to a pers se ing themselves to be the Defendant,to wit:James L Miller at 296 N. Old Stonehouse Rd., M dl x Tw .,Carlisle, PA 17013. 5 N ON, DEPUTY SHERIFF COST: $50.00 SO ANSWERS, February 26,2013 4RONANDERSON, SHERIFF !r;icunp5ufie eFrenY,TeiaosoR.Inc. Department of Defense Manpower Data Center Results as of:Jun-1 3-2013 11:41:16 SCRA 3.0 Status R,cpon want to Semicememben Civil Relief Act Last Name: MILLER First Name: JAMES Middle Name: L. Active Duty Status As Of: Jun-13-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA NA This response reflect ,heindivbuais'active duty status based on 1hdAcdve Duty Status Date Left Active Duty within 367 Days of Active:Duty Status Date Active Duty Start Date Active Duty Date Status Service Component NA NA No NA This response reflects where the individual left active duty status wiftn 367 days preceding the Active Duty Status Date The Member or His/Her tint Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification Erb Data Status Service Component NA NA u`'; „ '... .No ', `. NA This response reflects whether the individual ort is/her unit has received earfiynotifiwtion'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,NOAH,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. 01 • 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:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htm]. 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 maybe 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: D3WBVED2G053P40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA Plaintiff NO. 13 950 Civil vs. JAMES L.MILLER STEPHANIE L.MILLER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (hiips://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): STEPHANIE L. MILLER, has a last known residence of 296 Old Stonehouse Road, Carlisle, PA 17015. The following information was used to search the DMDC (check all that apply): x Last Name X First Name x Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 490 rel ing to unsworn falsification to thorities. Date l� By:M KL LAW G Michael McKeeve Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew GomalI Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Jun-1 32013 11:42:19 SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act I'll W_ Last Name: MILLER First Name: STEPHANIE Middle Name: L. Active Duty Status As Of: Jun-13-2013 On Active piny On Active Duty Status Date Active Duty Saar[Hate Active Duty End Date '. Status Service Component NA NA 4," °No NA This response reflects the hodMduats'active duty status based on the Active Duty.Status Date Left 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 statua wi hin 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a Future CaIF-Up to Active Dutym Adve Duty Status Date Order Notification Start Data Order Notification End Date Status Service'Conponent' NA NA .No' - NA This response reflects whether the individual oe hWher 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. • JAR- 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.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. 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: 73HF1 E32S0530E0 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY IN THE COURT OF COMMON PLEAS PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A of Cumberland County WASHINGTON MUTUAL BANK,FA c/o 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES L.MILLER STEPHANIE L.MILLER (Mortgagor(s)and Record owner(s)) No. 13 950 Civil 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHIN G ON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA,and against JAMES L.MILLE S P IE L.MILLER for failure to file an Answer in the above action within(20)days from the date of service o o plai in the sum of$358,984.08. By: KML LA-fV 01 P Michael McKeever Pa. D 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA o 3415 ision Drive Columbus,OH 43219 and that the name(s)and last known address(es)of the Defendant(s)is/are JAMES LLE ,296 Stonehouse Road Carlisle,PA 17015 and STEPHANIE L.MILLER,296 Old Stonehouse Road Carlisle,PA 17015- By: KMKL dR W, .C. OKeeN r Michael Pa.ID 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $296,442.21 Interest from 05/01/2010 through $49,036.47 01/31/2013 Reasonable Attorney's Fee $1,300.00 Late Charges $191.19 Escrow Advance $11,556.96 BPO/Appraisal $95.00 Property Inspection $362.25 $358,984.08 By: KML LAW,PROUV,P. . Michael McK ever Pa.ID 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua L Goldman Pa.205047 �Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff AND NOW,this (T` day of \Ui1L' ,20ebove. 0 Pro Prothy 13 950 Civil/10 2723FC Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13 950 Civil VS. JAMES L.MILLER STEPHANIE L.MILLER (Mortgagors and Record Owner(s)) 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 JP Prothonotary ob vb3w By: (0 /7//3 Deputy If you have any questions concerning the above,please contact: KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 1 „ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF IN THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA of Cumberland County c/o 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION—LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES L.MILLER STEPHANIE L.MILLER No. 13 950 Civil and Record Owner(s) 7;1 296 Old Stone House Road 4.0 = '+ Carlisle,PA 17013 xrn r `r Defendant(s) ter"" — C —<> '4 ._+ .,C G ..fl c PRAECIPE FOR WRIT OF EXECUTION c` c TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $358,984.08 Interest from 2/1/2013 to Date of Sale per diem at$36.55 (Costs to be added) 4(9.8 SO Pr' Arr'/ 50. 00 CE'1" 103.�5 " By: 'it L tt./ _ jj1(n .50 __..__._....._....._ KML L•V1 t . 117.,P.C. Iq� `�5 Pa AThi Michael cKeeve Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa.205047 4 a.d,5 Ile ( .i50. )'-Jill P.Jenkins Pa.ID 306588 � a5o Andrew F.Gornall Pa. ID 92382 a I Attorneys for Plaintiff e a4/1/0y �E (1.)ri+ .cJ KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY IN THE COURT OF COMMON PLEAS PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A of Cumberland County WASHINGTON MUTUAL BANK, FA c/o 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES L. MILLER STEPHANIE L. MILLER (Mortgagor(s) and Record Owner(s)) 296 Old Stone House Road No. 13 950 Civil Carlisle,PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA, Plaintiff in the above action,by counsel,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 296 Old Stone House Road Carlisle,PA 17013 C3 r- c 1.Name and address of Owner(s)or Reputed Owner(s): -403 w —1 r*l Cr) c_.. T3 JAMES L. MILLER Z rri 296 Old Stonehouse Road CIO�b• p Carlisle,PA 17015 r -1 c) c7 cY3`ri STEPHANIE L.MILLER m G ,r7S5 ri 296 Old Stonehouse Road . Carlisle,PA 17015 2.Name and address of Defendant(s)in the judgment: JAMES L. MILLER 296 Old Stonehouse Road Carlisle,PA 17015 STEPHANIE L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg,PA 17105-2675 CARLISLE CEMENT PRODUCTS,INC. 510 EAST NORTH STREET P.O.BOX 617 CARLISLE,PA 17013 4.Name and address of the last recorded holder of every mortgage of record: NEW CUMBERLAND FEDERAL CREDIT UNION 345 LEWISBERRY ROAD NEW CUMBERLAND,PA 17070 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 296 Old Stone House Road Carlisle,PA 17015 I verify that the statements made in this affidavit are true and correct to the best of my information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 1 By: 111)4 1_�I _' KML LA V ' I Iii;P.C. Michael McKeever 'a.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff 13 950 Civil KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE IN THE COURT OF COMMON PLEAS FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA of Cumberland County c/o 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES L.MILLER w - STEPHANIE L.MILLER r COI C— Fi d Mortgagor(s)and Record Owner(s) Docket No. 13 950 Circe 296 Old Stone House Road D .J c. Carlisle,PA 17013 �---� Defendant(s) A "° THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MILLER,JAMES L. JAMES L. MILLER 296 Old Stonehouse Road Carlisle,PA 17015 Your house at 296 Old Stone House Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$358,984.08 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13 950 Civil 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA,the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.nhiladelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BEI,OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 ti 13 950 Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a�kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 102723FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13 950 Civil KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE IN THE COURT OF COMMON PLEAS FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA of Cumberland County do 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES L.MILLER i--' STEPHANIE L.MILLER Mortgagor(s)and Record Owner(s) Docket No. 13 950 Civ co "Tl 296 Old Stone House Road 2 Carlisle,PA 17013 i" Defendant(s) X a j c F.i. cz THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO -- COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO 4". COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MILLER,STEPHANIE L. STEPHANIE L. MILLER 296 Old Stonehouse Road Carlisle,PA 17015 Your house at 296 Old Stone House Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 04,2013, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$358,984.08 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13 950 Civil 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA,the back payments, late charges,costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERI,AND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13 950 Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(&,,kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 102723FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK IN THE COURT OF F/K/A WASHINGTON MUTUAL BANK, FA COMMON PLEAS do 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW JAMES L. MILLER ACTION OF STEPHANIE L. MILLER MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 296 Old Stone House Road Carlisle, PA 17013 Defendant(s) NO. 13 950 Civil CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. c, „ w ---4 By: LtI ma)z r11 KML LAW F' •P .C. Michael Mc Mc eever P. 1D 56129 -<b Jay E. Kivitz Pa.ID 26769 ,< Lisa Lee Pa.ID 78020 3>c`: CD Kristina Murtha Pa. ID 61858 = ; David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 „-- Joshua I.Goldman Pa.205047 Jill P. Jenkins Pa. ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-950 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,Successor in interest by purchase from THE FDIC,as receiver of WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK,FA, Plaintiff(s) From JAMES L.MILLER& STEPHANIE L. MILLER (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:358,984.08 L.L.: $.50 Interest from 2/1/13 to Date of Sale per diem at$36.55 Atty's Comm: Due Prothy: $2.25 Atty Paid: $198.75 Other Costs: Plaintiff Paid: Date: 6/17/13 :bat(e.:AL—I----2/-J-L David D. B 11, Prothonot� (Seal) B Deputy REQUESTING PARTY: Name: JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP PC SUITE 5000-BNY INDEPENDENCE CETER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 306588 KML LAW GROUP,P.C. 102723FC Suite 5000 CF: 02/21/2013 .ti tit L SD: 12/04/2013 BNY Mellon Independence Center � �.� �-��� �2 r,��j��� ����.�� .,� � $3 58,984.08 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 NOV 1 b 4ti 10: 1 2 Attorney for Plaintiff C I M E R L y NU Oi COOURT OF COMMON PLEAS JPMORGAN CHASE BANK,NATIONAL ':.N P S Y ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF of Cumberland County WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA CIVIL ACTION—LAW c/o 3415 Vision Drive Columbus, OH 43219 ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Term No. 13 950 Civil JAMES L.MILLER STEPHANIE L.MILLER Mortgagor(s)and Record Owner(s) 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c)(2) Veronica Cosme,an employee of KML Law Group,P.C., counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult(copy of return attached). ( ) Certified mail by KML Law Group,P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group,P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). ( ) Certified Mail &ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail attached). ( ) Published in accordance with court order(copy of publication attached). Pursuant to the Affidavit under Rule 3129(copy attached), service on all lienholders(if any)has been made by ordinary mail KML Law Group,P.C.(copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, — :Y: Veronica Cosme Legal Assistant ■ O. r I \\O 1‘,(4,444A.,^0 *II 1 IS 1 N41")V V:), 0 , .% j- ---A-t 4031tHfl q �w�� N 7 "t A„141 f11 NA. ÷ iiillik o '4 ill 4,4 N 1666_ \ U O 101101:. \ c°• 4 0- Z@ k. e 4• dill y 0 7i:R0s s, p�N p. U �W O O Z 4 I-N r WZZ s Z., o m is N E G O d d t ° D W U 0 N c � R Z a z d a gs u.. .✓c4 o c co r d °0e. y .6 '. U ° o Dul i6 01 V c 'a j°OG to 0 W k _ © CC as �i4dv' t3 2W t3, N fl- ` 0 m i J 000 V °4U O ZN • N g Z p �Q d 1l� o gy -<-- a .. -j S. p O W G � i W W(d y a VZ a O 0 .„ rn -I N S ° lo N g fl .C4 cQ U -a „p V 7 L 0 oo m to. o °1 U� � wmNCb Qt • Z Z. N t3 0i5 00 0 pct° °0_U 0 °d W d r U j v C.) JN a -0 M M 0-0 -n to 0 % I Z o m p ti r d Y 21 06 IAA 1.0 N� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 09 0.81141 Jody S Smith r, Chief Deputy Richard W Stewart � ""' Solicitor o=i c.E OF THE&K RIFF JP Morgan Chase Bank vs. Case Number James L Miller(et al.) 2013-950 SHERIFF'S RETURN OF SERVICE 09/25/2013 11:42 AM -Deputy Jamie DiMartle, 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 296 N. Old Stone House Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. 09/30/2013 09:20 AM - Deputy Brian Grzyboski, 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 Stephanie L. Miller, Wife , who accepted as"Adult Person in Charge"for James L Miller at 296 N. Old Stonehouse Rd., Middlesex Twp., Carlisle, PA 17013, Cumberland County. 09/30/2013 09:20 AM-Deputy Brian Grzyboski, 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: Stephanie L. Miller at 296 N. Old Stone House Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. SHERIFF COST: $977.77 SO ANSWERS, October 23, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF of Cumberland County WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA c/o 3415 Vision Drive CIVIL ACTION-LAW Columbus,OH 43219 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term JAMES L.MILLER No. 13 950 Civil STEPHANIE L.MILLER Mortgagor(s)and Record Owner(s) 296 Old Stone House Road Carlisle,PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA,Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 296 Old Stone House Road Carlisle,PA 17013 1.Name and address of Owner(s)or Reputed Owner(s): JAMES L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 STEPHANIE L. MILLER 296 Old Stonehouse Road Carlisle,PA 17015 2.Name and address of Defendant(s)in the judgment: JAMES L. MILLER 296 Old Stonehouse Road Carlisle,PA 17015 • STEPHANIE L.MILLER 296 Old Stonehouse Road Carlisle,PA 17015 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 CARLISLE CEMENT PRODUCTS,INC. 510 EAST NORTH STREET P.O.BOX 617 CARLISLE,PA 17013 4.Name and address of the last recorded holder of every mortgage of record: NEW CUMBERLAND FEDERAL CREDIT UNION 345 LEWISBERRY ROAD NEW CUMBERLAND,PA 17070 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 296 Old Stone House Road Carlisle,PA 17015 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 12, 2013 /' L Law Group,P.C. BY: Veronica Cosme Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - Sheriff r u r 3 U a'�aiarrbe 1 _ r` Z��SOG LAR Jody S Smith �1l;i Chief Deputy � JAN 3 I AM 13, r. Richard W Stewart CUMSERLANO COUNTY Solicitor . ER`P' PENNSYLVANIA JP Morgan Chase Bank Case Number vs. James L Miller(et al.) 2013-950 SHERIFF'S RETURN OF SERVICE 09/25/2013 11:42 AM - Deputy Jamie DiMartle, 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 296 N. Old Stone House Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. 09/30/2013 09:20 AM - Deputy Brian Grzyboski, 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 Stephanie L. Miller, Wife , who accepted as"Adult Person in Charge"for James L Miller at 296 N. Old Stonehouse Rd., Middlesex Twp., Carlisle, PA 17013, Cumberland County. 09/30/2013 09:20 AM - Deputy Brian Grzyboski, 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: Stephanie L. Miller at 296 N. Old Stone House Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. 11/27/2013 As directed by Jill Jenkins, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/5/2014 01/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $788.95 SO ANSWERS, January 30, 2014 RONR ANDERSON, SHERIFF )Lf°� ad" qINC g1 30103 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-950 Civil Term JP MORGAN CHASE BANK vs. JAMES L.MILLER, Stephanie L. Miller Atty.:Jill Jenkins IMPROVEMENTS consist of a residential dwelling. BEING PREMISES:296 Old Stone House Road Carlisle,PA 17013. SOLD as the property of JAMES L. MILLER and STEPHANIE L.MILLER TAX PARCEL#21-08-0573-133. 87 f ~` 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. A)iL_, isa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 r 2 g;,,,ii,,,,i,. Notary CEt JRAH A COLLINS Notary Pubic LARLISLE BOROUGH,CUMAE'ERLAND COU.1 1TYw q My C mmiss;ori Expircs Apr 28 2811 i The Patriot-News Co. 2020 Technology Pkwy patriotXews 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 10/20/13 sofa-sso ChM 1 / _ vs. 10/27/13 BANK JP MORGAN CHASE . s, JAMES L MILLER SMphanIe L.MNlsr Atty: Jill Jenkins IMPROVEMENTS consist of a residential Swor to .n' subscribed before me t u 1 day of Novem o er, 2013 A.D. dwelling. BEING PREMISES:296 Old Stone House 1 I of JAMES L Road Carlisle,PA 17013 • SOLD as the property I I ( • MILLER and STEPHANIE L. MILLER w'. � TAX PARCEL#21-08-0573-133 `• - ' 'WAG bl Ic C;?^9MQrd`.AJEALTH OF PENNSYLVANIA '5P,M l:VI gt,, >•uphin County MY romrniseian ixpirgs Dm.12,2016 MEMBER,PENNSYLVANIA ASSO£G/ti"'ON OF NOTARIES