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HomeMy WebLinkAbout13-1219Guy Leroy ~. ! ~ ~ -~;= E(. t,:. at 6828 Torresdale Ave. l floor , s" "j ~~ ~- ,~' ~° ~ E j~~i~'~~, #~ Philadelphia PA 19135 (267}714-4186 7Q f 3 ~~~' - 5 ~~ ~ ~ ~ ~ ~ GUYLEROY ~~~~~~ ~'~~ ~~~'~ P'~~Y~~~AND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION -CIVIL VS. . HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK, FSB and all other persons unlmown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plaintiff s title Defendant(s) ~o ~s ~a~9 C~,> ACTION TO QUIET TITLE NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You aze wazned 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 fiuther notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 South Bedford Street Carlisle, PA 17013 Phone (717)-249-3166 Fax (717)-249-2663 ~. Ck,# 1 ~ I6(o~tG~ Guy Leroy 6828 Torresdale Ave. 1't floor Philadelphia PA 19135 (267'}714-4186 GUY LEROY Plaintiff VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 207-AS MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK, FSB and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plaintiff s title Defendant(s) CUMBERLAND COUNTY, PENNSYLVANIA COURT OF COMMON PLEAS TRIAL DIVISION -CIVIL NO: ACTION TO QUIET TITLE COMPLAINT FOR QUIET TITLE 1. The Plaintiff is GUY LEROY, an adult individual with a mailing address of 6828 Torresdale Avenue, ls` Floor Philadelphia, PA 19135. 2. Defendants are HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, a corporation with a current address believed to be at 3415 VISION DRIVE ,COLUMBUS, OH 43219. 3. Defendants are ONE WEST BANK, FSB, a corporation with a current address believed to be at 888 E. WALNUT STREET, PASADENA, CA 91141. 4. Additional defendants are all other persons unknown claiming any rights, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plaintiff's title. 5. With regard to those properties that were purchased by the Plaintiff or Plaintiffs agent at either a tax sale or repository sale, some or all of the sales conveyed title to Plaintiff, free and clear of all mortgages, judgments and other claims, pursuant to the real estate tax sale law. In the alternative it is believed and alleged that any mortgages, judgments and any other claims held by defendants have either been paid and not satisfied off record, nulUvoid by Pa statutes and should be stricken from the record. 6. If defendant makes claim, if any, then Plaintiff demands the amount due. 7. Defendant(s) HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE became judgment/ creditor/ lien holder via assignment from MERS as nominee for QUICKEN LOANS original mortgage recorded in mortgage Book: 1985 Page 1729 of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 09-11-3004-097, Being more described in a Cumberland county court house in Deed Book :234 Page: 326 . 8. Defendant(s) ONE WEST BANK, FSB became judgment/ creditor,/ lien holder Via assignment from FDIC AS RECEIVER FOR INDYMAC FEDERAL BANK, FSB, SUCCESSOR TO INDYMAC FSB ORIGINAL MORTGAGE RECORDED IN BOOK: 1985 PAGE: 1751. of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 09-11-3004-097, Being more described in a Cumberland county court house in Deed Book :1985 Page: 1751 . 9. On or about September 22~' 2011 the Cumberland County Tax Claim Bureau, by the powers vested in the pursuant to the Real Estate Tax Sale Law, 72 P.S. ss 5860.101 et seq., sold the property to Grantor. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for the nonpayment of taxes that constituted a valid lien on the property, to grantor, as the highest bidder at a public auction. 10. Plaintiff seeks a release of encumbrances against the subject property only, and does not request that liens if valid be removed from debtor's responsibility. 11. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. NO. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of ,any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. NO. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiffrespectfullypyays that your Honorable Court will enter an Order and Decree that states Plaintiff is the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. Respectfully submitted, uy ro ----- _ Guy Leroy 6828 Torresdale Ave. 1'` floor Philadelphia PA 19135 (267}714-4186 GUY LEROY CUMBERLAND COUNTY', PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION -CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-AS MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK, FSB NO: and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plainrtiff s title ACTION TO QUIET TITLE Defendant(s) . CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counseUdefendant(s) of record in this action. Service by certified mail, postage, prepaid was sent to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE 3415 VISION DRIVE COLUMBUS, OH, 43219 ONE WEST BANK, FSB 888 E. WALNUT STREET, PASADENA, CA 91101 BY: VERIFICATION I, Guy Leroy, verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3 ~/ 1~3 uy c- E O c NO1A ,. Guy Leroy 6828 Torresdale Ave. 1st floor 2013 J l I I AM 10: 57 Philadelphia PA 19135 (267)-714-4186 CUMBERLAND COUNTY PENNSYLVANIA GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. • HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) AND NOW, the Plaintiff, Guy Leroy, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case on March 5th 2013 (endorsed with a Notice to Defend). 1. The Defendant HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, was served by certified mail (endorsed with a Notice to Defend) on March 22nd 2013 and March 18th via certified mail at 3415 VISION DRIVE , COLUMBUS, OH 43219. Return Receipt attached as Exhibit "A". HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE was served 03/22/2013. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service. 2. The Defendant ONE WEST BANK, FSB, was served by certified mail (endorsed with a Notice to Defend) on March 18th 2013 via certified mail at 888 E. WALNUT STREET, PASADENA, CA 91101. Return Receipt attached as Exhibit "A". ONE WEST BANK, FSB was served 03/18/2013. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service. 3. 10 day notice was sent and respondent has failed to respond ( Exhibit B ) 4. The foregoing named Defendant is IN DEFAULT for their failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 5. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 6. Attached hereto is Plaintiff's Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as Exhibit "C". 7. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Default for failure to plead to Plaintiffs Complaint. Respectfully Submitted, Gu ero, Exhibit A • • r't • SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY • Complete Items 1,2,and 3.Also complete A.'Signatu. item 4 if Restricted Delivery Is desired. 0-Agent • Print your name and address on the reverse �j ❑Addresse4 so that we can return the card to you. r/Pred Name) ���pate pf■ Attach this card to the back of the mailpiece, o fu 1 v or on the front if space permits. v/ •. Is d: ery address different from Item 1? ❑Yes 1.Article Addressed to: If YES,enter delivery address below: ❑No • S" `1 e-" / `1 11 ° 1 3. Service Type❑Certified Mall ❑Express Mail D Registered ❑Return Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7 010 1870 0002 0 9 5 8 5128 (Transfer from service label) PS Form 3811,February 2004 Domestic Return Receipt 102595.02-M-1540 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY A. Signature • Complete items 1,2,and 3.Also complete �loop PAN_ item 4 if Restricted Delivery is desired. X 'AgegtsT,f • Print your name and address on the reverse / ❑Addresgee so that we can return the card to you. Re'- v e me) C DDatteof,DPJiyery • Attach this card to the back of the maiipiece, ZUU�W3 ' or on the front if space permits. ggS D. � �erq ai�dress different fran item 1? ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No n■ J 5A-n a-(2,066,_ r+S S6 Lt n-s=�a r aA Ti'4Sr�-C �.e. ,o.-Jc a,, rolorr j 3. Service Type IS— V t fii. al Certified Mail ❑Express Mall C O 0/116.).5, 64 "i 3Z(9 ❑Registered ❑Return Receipt for Merchandise 1 ❑Insured Mall ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7.010 1870 0002 0958 5111 11 (Transfer from service labeq --- --- — — PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 • • • Exhibit B . . . . • . . , . . . . . •,-, • . • „.. . . • • . • . • . . . • . , ,7--------7—. 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'4L z 3" -4 — z 0 . Ali . , j it. . . , kI-18$161000 OZ 1$ 000! . • 1 . Luusvimuvw iNnowu • WWI<MIMI El '6I Iddll EISI ff . . IAVEIIHd13°V1IHd , UP:id 30111S0d -s-n . , _ .. . i .. . . . . ...., ... f. . . . . , . . . . • . , . . . ' . . - . . . • . . • . . . . . . . . . - . • . : . • .-- . . . . . • . . . • .. .. . _ . . . ._ ... , Guy Leroy 6828 Torresdale Ave.l't floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY • CUMBERLAND COUNTY, • PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. • HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE • OF J.P.MORGAN MORTGAGE • TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant • AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any . right,title,estate,lien or interest in the real property described in the complaint adverse to Plaintiff's ownership,or any cloud to Plaintiff's title • ACTION TO QUIET TITLE Defendant(s) • NOTICE OF DEFAULT DATE:April 19TH,2013 To: ONE WEST BANK,FSB 888 E. WALNUT STREET,PASADENA, CA 91101. You have been sued in court. If you wish to defend against the claims set forth, you must take action within ten(10)days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle PA 17013 Guy Leroy 6828 Torresdale Ave.l`t floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS • TRIAL DIVISION-CIVIL VS. • • HSBC BANK USA NATIONAL • ASSOCIATION AS TRUSTEE • OF J.P.MORGAN MORTGAGE • TRUST 2007-A5 MORTGAGE • PASS THROUGH CERTIFICATES Defendant •• AND •• • ONE WEST BANK,FSB •• • NO: 13-1219 and all other persons unknown claiming any . right,title,estate,lien or interest in the real property described in the complaint adverse to Plaintiffs ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) NOTICE OF DEFAULT DATE: April 19TH,2013 To: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE 3415 Vision Drive, Columbus,OH 43219 You have been sued in court. If you wish to defend against the claims set forth, you must take action within ten (10)days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle PA 17013 Exhibit C Guy Leroy 6828 Torresdale Ave. 1St floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. • HSBC BANK USA NATIONAL • ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE • TRUST 2007-A5 MORTGAGE • PASS THROUGH CERTIFICATES • Defendant AND • ONE WEST BANK,FSB • NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiffs title • ACTION TO QUIET TITLE Defendant(s) • PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) The undersigned, being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Defendant was served by certified mail with a Complaint endorsed with a Notice to Defend: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, was served by certified mail (endorsed with a Notice to Defend) on March 22nd 2013 and March 18th via certified mail at 3415 VISION DRIVE, COLUMBUS, OH 43219. 2. The Defendant was served by certified mail with a Complaint endorsed with a Notice to Defend: ONE WEST BANK, FSB, was served by certified mail (endorsed with a Notice to Defend) on March 18th 2013 via certified mail at 888 E. WALNUT STREET, PASADENA, CA 91101. 3. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. 4. 10 day notice was sent and respondent has failed to respond ( Exhibit B. ) WHEREFORE, Defendant prays that the Court enter a judgment pursuant to PA.R.C.P. 1066(b)(3) granting the relief requested by Plaintiff. Guy Leroy Sworn to and subscribed before me this io day of 74„lri , 2013 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Roland V.Oris,Notary Public Notary Public City of Philadelphia,Philadelphia County M C9mmissi9n_Expires Sept 3o,2016 MEM R, of NOTARIES Guy Leroy 6828 Torresdale Ave. 1st floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant • AND ONE WEST BANK,FSB • NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) • CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon the Defendant this action. Service by usps mail, prepaid was sent to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, 3415 VISION DRIVE , COLUMBUS, OH 43219. ONE WEST BANK, FSB, 888 E. WALNUT STREET, PASADENA, CA 91101 �^ BY: Guy Leroy Guy Leroy 6828 Torresdale Ave. 1St floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL • ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE • TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES • Defendant AND • ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real : property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) CERTIFICATE OF ADDRESSES HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE, 3415 VISION DRIVE , COLUMBUS, OH 43219. ONE WEST BANK,FSB, /111111 888 E. WALNUT STREET, PASADENA, CA 91101 BY: Guy Leroy GUY LEROY, Plaintiff V, HSBC BANK USA NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION AS TRUSTEE OF J.P. OF THE NINTH JUDICIAL DISTRICT MORGAN MORTGAGE TRUST 2007- A5 MORTGAGE PASS THROUGH CERTIFICATES, and ONE WEST BANK, FSB, and ALL OTHER PERSONS UNKNOWN CLAIMING ANY RIGHT, TITLE, ESTATE, LIEN OR 2013-01219 CIVIL TERM INTEREST IN THE REAL PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF'S OWNERSHIP, OR ANY CLOUD TO PLAINTIFF'S TITLE, Defendants QUIET TITLE IN RE: MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) ORDER OF COURT AND NOW, this 24th day of June 2013, upon consideration of the Motion for Court Order Pa. R.C.P. No. 1066(b)(3), the motion is DENIED. A review of the file indicates the motion is defective as it lacks, inter alia, Return of Service and Specific Averments. Thomas A. Dlacey C.P.J. Distribution: Zuy Leroy ,/HSBC Bank USA National Association :Z' :q One West Bank, FSB XCD ---F1 Guy Leroy 6828 Torresdale Ave. 1"floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES H Defendant [✓ AND ''C E.r1 a C:) ONE WEST BANK,FSB NO i 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real property described in the complaint adverse : to Plaintiffs ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) , MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) AND NOW, the Plaintiff, Guy Leroy, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case.on March Stn 2013 (endorsed with a Notice to Defend). 1. The Defendant HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, was served by certified mail (endorsed with a Notice to Defend) on March 22nd 2013 via certified mail at 3415 VISION DRIVE , COLUMBUS, OH 43219. Return Receipt attached as Exhibit "A". HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE was served 03/22/2013. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service. 2. The Defendant ONE WEST BANK, FSB, was served by certified mail (endorsed with a Notice to Defend) on March 18th 2013 via certified mail at 888 E. WALNUT STREET, PASADENA, CA 91101. Return Receipt attached as Exhibit "A". ONE WEST BANK, FSB was served 03/18/2013. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service. 3. More than 20 days have passed. 4. 10 day notice was sent and respondent has failed to respond ( Exhibit B ) 5. More than 10 additional days have passed. 6. The foregoing named Defendants are IN DEFAULT for its failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 7. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 6. Rule 410(a) merely provides that "[i]n actions involving title to, interest in, possession of, or charges or liens upon real property, original process shall be served upon the defendant in the manner provided by Rule 400 et seq." Rule 404(2) allows service outside the Commonwealth to be made "by mail in the manner provided by Rule 403." Rule 403 in turn allows service to "be mailed to the defendant by any form of mail requiring a receipt signed by the defendant or his authorized agent." Complaints for Quiet Title under Pa.R.C.P. can therefore be properly served upon out-of-state defendants by certified mail pursuant to Pa.R.C.P. 403. 8. Attached hereto is Plaintiffs Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as Exhibit "C". 9. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Default for failure to plead to Plaintiffs Complaint. Respectfully Submitted, —L /y ero Exhibit A Guy Leroy 6828 Torresdale Ave. 15t floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION -CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES . Defendant . AND ONE WEST BANK, FSB . NO: 13-1219 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff's ownership, or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) . RETURN OF SERVICE I, Guy Leroy, hereby certify that a complete, true and correct copy of the Action to Quiet Title Notice and related pleadings and exhibits have been served upon the Defendant, HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES, 3415 VISION DRIVE COLUMBUS OH 43219 by United States Certified Mail with signature required, received on March 22nd 2013 AND ONE WEST BANK 888 E WALNUT ST. PASADENA, CA 91101 by United States Certified Mail with signature required, received on March 18th 2013. True and correct copies of the enclosure letter and signed receipt are attached hereto and collectively marked as Exhibit "A". Date: v, 3 BY: G eroy Sworn to and subscribed before me this t s' day of�� , 2013 Notary Public Commo�,ca-,FALTH OF PENNSYLVANIA �- NotIM Seal Roland V,oris,Notsy Pubk EcmrvyCommLsslon of Pfiliadelphla,PhladeVM COuntY Expires 30,20_i-.5__ tTEMSER,PENriSr._�A+.fA ASSOMMOII Of„ I ARIES COMMONWEALTH OF PENNSYLVANIA Notarial seal Roland V.Otis,Notary Publk City of Phlladelphla,PhllaWphla County C9fnlftW raa 30,2016 °MHM NOTAkM- EXHIBIT . A Guy Leroy 6828 Torresdale Ave. Vt floor Philadelphia PA 19135 GUYLEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION -CIVIL HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK, FSB NO: 13-1219 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse, to Plaintiff's ownership, or any cloud to Plaintiff's title ACTION TO QUIET TITLE CERTIFICATE OF SERVICE 1, Guy Leroy certify that a true and correct copy of the foregoing Return of Service was served upon the following on the date below by mailing a copy of the same by first class mail, postage prepaid, addressed to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE 3416 VISION DRIVE COLUMBUS, OH, 43219 ONE WEST BANK, FS13 888,E. WALNUT STREET, PASADENA, CA 91101 ' SENDER: COMPLETE THIS • tr+rmryr�r�rr:��-r�arra.•r.�w.�y.ni �• ■ Complete items 1,2,and 3.Also complete A."Signatu item 4 if Restricted Delivery is desired. y CI-Agent ■ Print your name and address on the reverse �` _ ❑Addre_ssc so that we can return the card to you.• Y ce ve � (P Yfted Name) jWar pf■ Attach this card to the back of the mailpiece, vv �LvY or on the front if space permits. 1: Article Addressed to: D. Is d ery address different from Item 1? ❑Yes If YES,enter delivery address below: ❑No �• a q 3. Service Type ( � E3 Certified Mail ❑Express Mail P Registered ❑Return Receipt for Merchandic ❑Insured Mail ❑C.O.D. [. Restricted Delivery?(Extra Fee) D Yes 2. Article Number 7U10 1870 0002 0 9 5 8 5128 (Transfer from servIce labeq Ps Form 3811,February 2004 Domestic Return Receipt 102595-02-M-15 SENDER:COMPLETE THIS SECTIO ■ Complete items 1,2,and 3.Also complete A Signature ��pND fiAR r item 4 if Restricted Delivery is desired. X ��Ag�rt9�9, ■ Print your name and address on the reverse �. ❑Addres-0; so that we can return the card to you.. Re' a e) C Date of Del'Wer ■ Attach this card to the back of the mailpiece, C kTr'1R 1. LUU'i3 or on the front if space permits. ' , D. 621APiVa ' ress different from, item 1? ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No 44 6E nK JS-Ar) t'�onKI 3. Service Type Certified Mail ❑Express Mail C one 5 d 3Ze� ❑Registered ❑Return Receipt for Merchandie- / ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7010 1870 -0002 0958' 5111 1 (Transfer from service_laben PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-te Exhibit B U.S.POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL.MAIL.DOES NOT .- PROVIDE FOR INSURANCE Pa3TMA3TER �° „� Xe Lq b was 'f Ona�acaaford'r�say�/m�,ayd�ae�rssstadrta_:�,,, �r y�!� if o'�' � a y f • - L7�/3 G f:��t11�/'1c I�aY� �,. ,a� w a m - .. PS Farm 3817,January 2001 M ' ' � 1 U.S.POSTAL SERVICE CERTIFICATE OF MAILING WAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL,DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ' ReeeNed Fldrc 3 I ii 1 Weae of oN6rery men eAmres W to: c K J S4 N r• S511G'AYfry+ •t7VS+�[ o'f' J r� °1••,�(Or�lk__ .'..� w a � . ,}YJIs a-5, �olo D1I D 43V PS Form 3817,January 2001 L Guy Leroy 6828 Torresdale Ave.1"floor Philadelphia PA 19135 (267)-7144186 GUY LEROY . CUMBERLAND COUNTY, PENNSYLVANIA. Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. I . C HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO:13-1219 and all other persons unknown claiming any right,title,estate,lien or interest in the real property described in the complaint adverse to Plaintiffs ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) i NOTICE OF DEFAULT DATE:April 19TH,2013: To: ONE WEST BANK,FSB 888 E.WALNUT STREET,PASADENA,CA 91101. You have been sued in court. if you wish to defend against the claims set forth,you must take action within ten(10)days after this complaint and notice are served,by entering a written appearance personally or by attorney and filing In writing with the court your defenses or objections to the claims set forth against you.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER . LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle PA 17013 f Guy Leroy 6828 Torresdale Ave.1``floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO:13-1219 and all other persons unknown claiming any right,title,estate,lien or interest in the real property described in the complaint adverse to Plaintiff's ownership,or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) NOTICE OF DEFAULT DATE:April 19TH;2013 To: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE 3415 Vision Drive,Columbus,OH 43219 You have been sued in court.If you wish to defend against the claims set forth,you must take action within ten(10)days after this complaint and notice are served,by entering a written appearance personally or by attorney and filing In writing with the court your defenses or objections to the claims set forth against you.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle PA 17013 t t Exhibit C Guy Leroy 6828 Torresdale Ave. V floor Philadelphia PA 19135 (267)-714-4186 GUYLEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real : property'described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) The undersigned, being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Defendant was served by certified mail with a Complaint endorsed with a Notice to Defend: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, was served by certified mail (endorsed with a Notice to Defend) on March 22nd 2013 and March 18th via certified mail at 3415 VISION DRIVE, COLUMBUS, OH 43219. 2. The Defendant was served by certified mail with a Complaint,endorsed with a Notice to Defend: ONE WEST BANK, FSB, was served by certified mail (endorsed with a Notice to Defend) on March 18 th 2013 via certified mail at 888 E. WALNUT STREET, PASADENA, CA 91101. 3. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within.twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. 4. 10 day notice was sent and respondent has failed to respond ( Exhibit B. WHEREFORE, Defendant prays that the Court enter a judgment pursuant to PA.R.C.P. 1066(b)(3) granting the relief requested by Plaintiff. ,—,-Guy Leroy Sworn to and subscribed before me this _L_day of 12013 Notary Public c0mmoNVVmTH OF PENNSYLVANIA- 'Naartai seal RoWnd V.Orls,Noiary Public oty of Philadelphia,.Philadelphia COur'tV my commission E)Vres sepL 30,2016 MEMBER,KNNMVANIA ASR)UATION LX_NOTAR'ES r i Exhibit s f C i Guy Leroy 6828 Torresdale Ave. 1"floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real : property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon the Defendant this action. Service by usps mail, prepaid was sent to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE, 3415 VISION DRIVE , COLUMBUS, OH 43219. ONE WEST BANK,FSB, 888 E. WALNUT STREET, PASADENA, CA 91101 BY: Guy Leroy i Guy Leroy 6828 Torresdale Ave. lit floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL . ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND . ' r ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) CERTIFICATE OF ADDRESSES HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, 3415 VISION DRIVE , COLUMBUS, OH 43219. ONE WEST BANK,FSB, 888 E. WALNUT STREET,PASADENA, CA 91101 BY: Guv Lerov Guy Leroy 6828 Torresdale Ave. 15t floor Philadelphia PA 19135 (267)-714-4186 GUY_ LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE ; TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES MCO Defendant - AND CD -ri ONE WEST BANK, FSB NO: 13-1219 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff's ownership, or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) RETURN OF SERVICE I, Guy Leroy, hereby certify that a complete, true and correct copy of the Action to Quiet Title Notice and related pleadings and exhibits have been served upon the Defendant, HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES, 3415 VISION DRIVE , COLUMBUS. OH 43219 by United States Certified Mail with signature required, received on March 22nd 2013 AND ONE WEST BANK 888 E WALNUT ST. PASADENA, CA 91101 by United States Certified Mail with signature required, received on March 18th 2013. True and correct copies of the enclosure letter and signed receipt are attached hereto and collectively marked as Exhibit "A". Date: V° 3 BY: G eroy Sworn to and subscribed before me this day of 2013 Notary Public CUmhto wv,EALTH OF PENNSYLVANtA /r Notarial Seal Roland V.Ori;,Notary Public City of Phaadelphta,K4adclphla County My Commissbn Eio a 30,20,5 mEmSf.R,Pr.n%sr.+A#-tA AssoaA7ok of wt AF' s COMMONWEALTH OF PENNSYLVANIA Notarial Seal Roland V.Otis,Notary Public City of Phitadelphlo,PhOaMphla County CclmmOan 90rft 30,2016 .141MOM MNMVAWA ANIOCKHON OF NOTARIES' EXHIBIT A Guy Leroy 6828 Torresdale Ave. 1St floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND . ONE WEST BANK, FSB NO: 13-1219 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff's ownership, or any cloud to Plaintiff's title ACTION TO QUIET TITLE Defendant(s) CERTIFICATE OF SERVICE I, Guy Leroy certify that a true and correct copy of the foregoing Return of Service was served upon the following on the date below by mailing a copy of the same by first class mail, postage prepaid, addressed to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE 3415 VISION DRIVE COLUMBUS, OH, 43219 ONE WEST BANK, FSB 888 E. WALNUT STREET, PASADENA, CA 91101 DATED: ( �3 BY Guy'%fro l n V t • • • • DELIVERY ■ Complete items 1,2,and 3.Also complete Kn item 4 if Restricted Delivery is desired. a-Agent ■ Print your name and address on the reverse ❑Addressed so that we can return the card to you. P rlted Name) ate f 90d■ Attach this card to the back of the mailpiece, / Lug or on the front if space permits.1.� Article Addressed to: ress different from Item 1? ❑Yes # I If YES,enter delivery address below: ❑No +_ n S a 3 C]Certified Mail ❑Express Mail GI Registered ❑Return Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number j 7010 1870 0002 0 9 5 8 5128 (transfer from servfce labeo Ps Form 3811,February 2004 Domestic Return Receipt 102595-02-M-154( COMPLETE • . .. •. . ►�a- ■ Complete items 1,2,and 3.Also complete A. Signature ati��o pqR item 4 if Restricted Delivery is desired. X ❑'A9egt�T� ■ Print your name and address on the reverse t ❑Addressee so that we can return the card to you. Rey a me) C. Date of p`e�Wery ■ Attach this card to the back of the mailpiece, �Q �H 1.1 �U13 or on the front if space permits. D. iliJts ress different from item 1? ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No r -S56 C'kn{far. 3. Service Type 0 Certified Mall ❑Express Mail 6 ' DMI 6 r I j Z` [3 Registered E3 Return Receipt for Merchandise t ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number; : ; ��1� 1870 0002 0958' 5.111 (transfer from service labeo _ .-— - PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 a GUY LEROY, Of Plaintiff 1*00R !""Ibu V. tqzt HSBC BANK USA NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION AS TRUSTEE OF J.P. OF THE NINTH JUDICIAL DISTRICT MORGAN MORTGAGE TRUST 2007- A5 MORTGAGE PASS THROUGH CERTIFICATES, and ONE WEST BANK, FSB, and ALL OTHER PERSONS UNKNOWN CLAIMING ANY RIGHT, TITLE, ESTATE, LIEN OR 2013-01219 CIVIL TERM INTEREST IN THE REAL PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF'S OWNERSHIP, OR ANY CLOUD TO PLAINTIFF'S TITLE, Defendants QUIET TITLE IN RE: MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) ORDER OF COURT AND NOW, this day of August 2013, upon consideration of the Motion for Court Order Pa. R.C.P. No. 1066(b)(3), the motion is DENIED. A review of the file indicates the motion is defective as it lacks, inter alia, Specific Averments. BY THE COURT, Thomas . Placey C.P.J. /Distribution: r, -•J /Guy Leroy ASBC Bank USA National Association ' '' ; ,/One West Bank, FSB . c-j - 5c W wry V(6 a Guy Leroy 6828 Torresdale Ave. 1St floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION- CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE , TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant �. AND cC)� C ONE WEST BANK,FSB NO: 13.1219 and all other persons unknown claiming any : right,title, estate,lien or interest in the real property described in the complaint adverse : to Plaintiffs ownership,or any cloud to Plaintiff s title AMENDED ACTION TO QUIET TITLE Defendant(s) NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth,you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 South Bedford Street Carlisle, PA 17013 Phone(717)-249-3166 Fax(717)-249-2663 I Guy Leroy 6828 Torresdale Ave. 1"floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiffs title AMENDED ACTION TO QUIET TITLE Defendant(s) AMENDED COMPLAINT FOR QUIET TITLE 1. The Plaintiff is GUY LEROY, an adult individual with a mailing address of 6828 Torresdale Avenue, 1St Floor Philadelphia, PA 19135. 2. Defendants are HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE, a corporation with a current address believed to be at 3415 VISION DRIVE , COLUMBUS, OH 43219. 3. Defendants are ONE WEST BANK,FSB, a corporation with a current address believed to be at 888 E. WALNUT STREET, PASADENA, CA 91101. 4. The plaintiff Guy Leroy purchased and has actual ownership of the premises paid in full on September 22nd 2011 known as 505 Leeward Lane, East Pennsboro Township, Cumberland County, Pennsylvania , Folio number 09-11-3004-097 at a Upset Tax sale Held on September 22nd 2011 from the Comberland County Tax Claim Bureau . 5. Additional defendants are all other persons unknown claiming any rights, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff's ownership, or any cloud to Plaintiffs title. 6. A complete legal description of the subject Premise is attached hereto and made part hereof as ( EXHIBIT A) 7. With regard to those properties that were purchased by the Plaintiff or Plaintiffs agent at either a tax sale or repository sale, some or all of the sales conveyed title to Plaintiff, free and clear of all mortgages,judgments and other claims, pursuant to the real estate tax sale law. In the alternative it is believed and alleged that any mortgages,judgments and any other claims held by defendants have either been paid and not satisfied off record, null/void by Pa statutes and should be stricken from the record. 8. If defendant makes claim, if any, then Plaintiff demands the amount due. 9. Defendant(s) HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE became judgment/ creditor/ lien holder via assignment from MERS as nominee for QUICKEN LOANS original mortgage recorded in mortgage Book: 1985 Page 1729 of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 09-11-3004-097, Being more described in a Cumberland county court house in Deed Book : 234 Page: 326 . 10. Defendant(s) ONE WEST BANK, FSB became judgment/ creditor/ lien holder Via assignment from FDIC AS RECEIVER FOR INDYMAC FEDERAL BANK, FSB, SUCCESSOR TO INDYMAC FSB ORIGINAL MORTGAGE RECORDED IN BOOK: 1985 PAGE: 175 1. of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 09-11-3004-097, Being more described in a Cumberland county court house in Deed Book : 1985 Page: 1751 . 11. On or about September 22 2011 the Cumberland County Tax Claim Bureau, by the powers vested in the pursuant to the Real Estate Tax Sale Law, 72 P.S. ss 5860.101 et seq., sold the property to Grantor. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for the nonpayment of taxes that constituted a valid lien on the property, to grantor, as the highest bidder at a public auction. 12. Plaintiff seeks a release of encumbrances against the subject property only, and does not request that liens if valid be removed from debtor's responsibility. 13. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. NO. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of , any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. NO. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states Plaintiff is the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. Respectfully submitted, ,Guy ero E- XHIBIT A, "L ER -F DEEDS iU?A iiL6a tiJ COUNTY-PA '01 SEP 6 PPl 2 21 Tax Parcel No. 09-11-3004-097 THIS CORRECTIVE DEED, MADE this 23A 4day of August in the year Two Thousand and One (2001). BETWEEN MANUEL CORDEIRO and DRENDA S. CORDEIRO, husband and wife, of Cumberland County, Pennsylvania, hereinafter referred to as Grantors, party of the first part, -AND - MANUEL CORDEIRO and DRENDA S. CORDEIRO, husband and wife, as tenants by the entireties, of Cumberland County, Pennsylvania, hereinafter referred to as Grantees, parties of the second part. WITNESSETH, that in consideration of One and 00/100 Dollar($1.00) and other good and valuable consideration, in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey to the said Grantees, their successors and assigns: ALL THAT CERTAIN piece, parcel or lot of lands situate in East Pennsboro Township, Cumberland County, Pennsylvania; designated as Unit No. RB 8 on the Preliminary/Final Subdivision Plan by Rettew Associates, for River Bend, A Planned Community dated November 15, 1996, last amended January 7, 1999 and recorded in the Office of the Recorder of Deeds in and for Cumberland County on February 24, 1999, in Plan Book 78, Page 75, and being designated as Unit No. RB 8 in a Declaration of River Bend, A Planned Community, dated October 9, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 591, Page 477; also designated as Unit No. RB 8 on the Final Subdivision and Lot Add-On Plan for Wright, Cordeiro & River Bend Subdivision, prepared by Rettew Associates, Inc., dated July 13, 2001, being further bounded and described as follows, to wit: BEGINNING at a point on the Southern right-of-way line of Leeward Lane at the Northwest corner of Lot No. RB 7 of RiverBend; thence along said Lot South 00 degrees 27 minutes 55 seconds West, a distance of 263.55 feet to a point on the Northern line of Lot No. 5 of River Bend as recorded in Plan Book 65, Page 123; thence along said Lot and also along Lot No. 4 of RiverBend South 84 degrees 03 minutes 28 seconds West, a distance of-125.81 feet to an existing stone corner; thence continuing along Lot No.4 of River Bend,-,,South 60 degrees 05 minutes 38 seconds West, a distance of 2.6.95 feet to a poin't-at the Southeast comer of lands now or formerly of John A. and Bonita M. Wright; thence.along said lands of Wright, the following three (3) 'jl.courses*! orth-13 degrees=09 minutes 22 seconds=West; a distance of'155.53 feet , w ." l�r �! rClb FW' Page 1 of �" a r * !CR E DEEDS �U?AL`;iL,M;J COUNTY-PA '01 SEP 6 P11 2 2 9 Tax Parcel No. 09-11-3004-097 THIS CORRECTIVE DEED, MADE this 23A`eday of August in the year Two Thousand and One (2001). BETWEEN MANUEL CORDEIRO and DRENDA S. CORDEIRO, husband and wife, of Cumberland County, Pennsylvania, hereinafter referred to as Grantors, party of the first part, -AND - MANUEL CORDEIRO and DRENDA S. CORDEIRO, husband and wife, as tenants by the entireties, of Cumberland County, Pennsylvania, hereinafter referred to as Grantees, parties of the second part. WITNESSETH, that in consideration of One and 00/100 Dollar($1.00) and other good and valuable consideration, in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey to the said Grantees, their successors and assigns: ALL THAT CERTAIN piece, parcel or lot of lands situate in East Pennsboro Township, Cumberland County, Pennsylvania; designated as Unit No. RB 8 on the Preliminary/Final Subdivision Plan by Rettew Associates, for River Bend, A Planned Community dated November 15, 1996, last amended January 7, 1999 and recorded in the Office of the Recorder of Deeds in and for Cumberland County on February 24, 1999, in Plan Book 78, Page 75, and being designated as Unit No. RB 8 in a Declaration of River Bend, A Planned Community, dated October 9, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 591, Page 477; also designated as Unit No. RB 8 on the Final Subdivision and Lot Add-On Plan for Wright, Cordeiro & River Bend Subdivision, prepared by Rettew Associates, Inc., dated July 13, 2001, being further bounded and described as follows, to wit: BEGINNING at a point on the Southern right-of-way line of Leeward Lane at the Northwest corner of Lot No. RB 7 of RiverBend; thence along said Lot South 00 degrees 27 minutes 55 seconds West, a distance of 263.55 feet to a point on the Northern line of Lot No. 5 of River Bend as recorded in Plan Book 65, Page 123; thence along said Lot and also along Lot No. 4 of RiverBend South 84 degrees 03 minutes 28 seconds West, a distance of 125.81 feet to an existing stone corner; thence continuing along Lot No. 4 of River Bend, South 60 degrees 05 minutes 38 seconds West, a- distance of 26:95,feet to a point at the Southeast corner of lands now or formerly of -John A. and Bonita M.Wright thence along said lands of Wright, the following three(3) courses: (1) North:13 degrees 09 minutes 22 seconds West, a distance of 155.53 feet Page 1 of 3 n -id Fri 14 t ,, ��`' #�..� , t "� I xti# �-,��#.3 � �a'� `x`35., r ?r" tx 'FA. • r r w. n -w., ., ,Z,. S 4. ,-, B "31F, C ,.1••4i a ,! �' to a point; (2) North 23 degrees 03 minutes 49 seconds West, a distance of 86.90 feet to a point; (3) North 72 degrees 43 minutes 44 seconds East, a distance of 102.15 feet to a point on the cul-de-sac bulb of Leeward Lane; thence along said bulb by a line curving to the left having a radius of 50.00 feet, an arc length of 100.31 feet and a chord bearing of North 81 degrees 40 minutes 48 seconds East, a distance of 84.31 feet to a point at the Western terminus of a 20 foot radius curve connecting the cul-de- sac bulb of Leeward Lane to the Southern right-of-way line of Leeward Lane; thence along said curve, by a line curving to the right having a radius of 20.00 feet, an arc length of 19.25 feet and a chord bearing of North 51 degrees 47 minutes 03 seconds East, a distance of 18.52 feet to point on the Southern right-of-way line of Leeward Lane; thence along the Southern right-of-way line of Leeward Lane, North 79 degrees 21 minutes 34 seconds East, a distance of 25.00 feet to a point, the Place of BEGINNING. CONTAINING 1.01 acres and being Lot RB 8, as shown on the Final Subdivision and Lot Add-On Plan for Wright, Cordeiro & RiverBend Subdivision, prepared by Rettew Associates, Inc., dated July 13, 2001. BEING a portion of the same premises which Alan S. Meminger, a married man, by deed dated March 24, 1998 and recorded March 27, 1998, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 174, Page 200, granted and conveyed to River Bend Management Limited Partnership, Grantor herein. ALSO BEING part of the same property which RiverBend Management Limited Partnership, by its Deed dated November 17, 2000 and recorded November 20, 2000, in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book. 234, Page 326, granted and conveyed unto Manual Cordeiro and Drenda S. Cordeiro, husband and wife. THIS CORRECTIVE DEED is being recorded to change the description based on the Final Subdivision and Lot Add-On Plan for Wright, Cordeiro & RiverBend Subdivision, prepared by Rettew Associates, Inc., dated July 13, 2001. AND SUBJECT, NEVERTHELESS, to any and all liens, mortgages, easements, covenants, conditions, restrictions, reservations, rights-of-way, zoning ordinances, building lines and any and all other matters that are of record or visible on the premises. TOGETHER with all and singular the building improvements, tenements, hereditaments and appurtenances to the same belonging, or in any wise appertaining, andeversion and reversions, remainder and remainders, rents, issues and profits :thereof, and also all of the estate, right, title, interest, property, claim and demand whatsoever, both in law and equity, of the said Grantor, of, in, and to or out of the .same. AND the Grantor hereby covenants and agrees that they will warrant specially the property hereby conveyed. Y �9e 2 of 3 _ buix 246 F.,6Ei4G5 ekv t w f r_ av¢..asaw4 IN WITNESS WHEREOF, the said Grantor, has hereunto duly executed this Deed, the day, month, and year first above written. WITNESS: A L i r anual Corde' o Ale 60'-�44� Drenda (Cor COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF BftPH N-QIbzs kq)d )ss. On this, the of August, 2001, before me, the undersigned officer, personally appeared Manual Cordeiro and Drenda S. Cordeiro, husband and wife, known to me (or satisfactorily proven)to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. �* Notarial Sez! +' y Jeannie Y.Jameson,Notary Public Hampden Twp.,Cumberland Coun S,4J�p! , , My Commission Expires Aug.30,2 Member,Pennsyivania Association of Notaries '9r HEREBY CERTIFY that the pr ci a residence and complete post office address of the (�aQtioiifyrdtisstosbeqmcor Wue, Enola, PA 17025. In Cumberland County PA Date Attorney for Grantee Recorder of Deeds bujX 246 46440 „*c Page 3 of 3 , :%... ..,..n- Nowte... ...'� t ,...., . ..,• .. , - REV-0e3 Ex Is%i RECORDER'S USE ONLY Stan Tax Paid REALTY TRANSFER TAX Octal,N COMMONWEALTH OF PENNSYLVANIA STATEMENT OF VALUE DEPARTMENT OF REVENUE page Nurnber BUREAU OF INDIVIDUAL TAXES HARRISBURG,PA8M171284W3 See Reverse for Instructions at.Recorded Complete each section and file in duplicate with Recorder of Deeds when(1)the full value/consideration is not set forth in the deed,(2)when the deed is without consideration,or by gift,or(3)a tax exemption is claimed.A Statement of Value is not required if the transfer is wholly exempt from tax based on: (1)family relationship or(2) public utility easement. If more space is needed,attach additional sheet(s). A CORRESPONDENT - All inquiries may be directed to the following person: Name Telephone Number. Manuel Cordeiro and Drenda S. Cordeiro Area Code( ) Street Address city State Zip Code 80 Queen Avenue Enola PA 17025 S TRANSFER DATA Date Acceptance of DOCument Grantar(s)/ essor(s) Grantees)/Lessee(:) Manuel and Drenda S. Cordeiro Manuel and Drenda S. Cordeiro Street Address treat A ress 80 Queen Avenue 80 Queen Avenue City State Zip Code City State Zip Code Enola PA . 17025 Enola PA 17025 C PROPERTY LOCATION Street Address City,Township,Borough Lot No. 8, River Bend East Pennsboro Township County Schoo District Tax Parcel Number Cumberland East Pennsboro 09-11-3004-097 D VALUATION DATA 1.Actual Cash Consideration 2.Other Consideration 3.Total Consideration $1.00 .f. 501 $1.00 7 County Assessed Value 5.Common Level Ratio Fodor b.Fair Market Value X E EXEMPTION DATA Ia.Amount of xemption aim P b.Percentage of Interest Conveys 2. Check Appropriate Box Below for Exemption Claimed ❑ Will or intestate succession (Name of Decedent) (Estate Fib Number) ❑ Transfer to Industrial Development Agency. ❑ Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ❑ Transfer between principal and agent. (Attach complete copy of agency/straw party agreement.) ❑ Transfers to the Commonwealth,the United States and Instrumentalities by gift,dedication,condemnation or in lieu of condemnation. (If condemnation or in lieu of condemnation,attach copy of resolution.) ❑ Transfer from mortgagor to a holder of a mortgage in default. Mortgage Book Number , Page Number ER Corrective or confirmatory deed. (Attach complete copy of the prior deed being corrected or confirmed.) ❑ Statutory corporate consolidation, merger or division. (Attach copy of articles.) ❑ Other(Please explain exemption claimed,if other than listed above.) Under Postal ies of law,I dedan that 1 have examtmd this StetemeM,ineluditsg accompanying infermotion,and to the best of my kttewbdge M and belief-ft U-truer eorr hand eemplete: Skmakn of Correspondent er Responsi a Party Date �" ., k• y. FAILURE TO COMPLETE THIS FORM PROPERLY OR ATTACH APPLICABLE DOCUMENTATION MAY RESULT IN TIDE j I(ORDER'S REFUSAL TC!RECORD THE �y UJK: 24� PAGt].�} V k �". -, fi.� y^-✓ .a: ar"q3'i i:m*rc�i`�.c+.z see r_"a��✓`f�e3�4}x"t'recKi ..�eww,�. Guy Leroy 6828 Torresdale Ave. 1st floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION-CIVIL VS. HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES Defendant AND ONE WEST BANK,FSB NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiffs title ACTION TO QUIET TITLE Defendant(s) CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel/defendant(s) of record in this action. Service by certified mail, postage, prepaid was sent to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P.MORGAN MORTGAGE 3415 VISION DRIVE COLUMBUS,OH,43219 ONE WEST BANK,FSB 888 E.WALNUT STREET, PASADENA, CA 91101 BY: G LE VERIFICATION I, Guy Leroy, verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: j 2—3 Gu eroy --- Guy Leroy 6828 Torresdale Ave. 1s`floor Philadelphia PA 19135 (267)-714-4186 • GUY LEROY • CUMBERLAND COUNTY, • PENNSYLVANIA Plaintiff • COURT OF COMMON PLEAS • TRIAL DIVISION- CIVIL VS. • HSBC BANK USA NATIONAL • ASSOCIATION AS TRUSTEE • OF J.P.MORGAN MORTGAGE • t.i TRUST 2007-A5 MORTGAGE ' `'' PASS THROUGH CERTIFICATES • r Defendant AND - { r - - ONE WEST BANK,FSB ` NO: 13-1219 and all other persons unknown claiming any : right,title,estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff s title AMENDED ACTION TO QUIET TITLE Defendant(s) • CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon Defendants in this action. Service by first class usps, postage, prepaid was sent to: One West Bank, FSB 888 E. Walnut st Pasadena, CA 91101 D A T E D: / ' —/--J BY: —,...0//11411/ �y . . . . , . . . . . . • . • • . , ' . — _ ... - ' U.S.POSTAL SERVICE CERTiFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL,DOES NOT PROVIDE FOR INSURANCE-POSTMASTER 8§ Received From: ' ■ :-)7 4 //-,<A■-4/-) ,1 rj ' 7 o c-,2-70 0, *ie-,r.."--- 5401,(r, y(-cie 1 C-Q-749 • i„, . ,./( 4eP1 '(.../,. 04 ( '(-3 n----- One piece of ordinary mail addressed to: -1:3 3 6.- P.,,,-„r,. .,„ OS e' .4 A----- y4LQ 4 7 -- :■--.-L- , ,,_... , ,,,-, -z-v--...,:4 2,- -7-2,3,5 ril L.,--(6,,,,-, pA2,--s —1—b-A.H,JJ, OD. 3Lf Ls . C.) ( ) ( 1 0 2) P S Form 38"1741,J ta n i,'j2 y 210 0 C-) -it 1 k" 11 3 2 TO i 1 U.S. FOS-TAGE l' PHILRDELPHIA.PO 19135 DEMNT , . , • D'1• 2-1 I POSTAL SERVICE 13 fl:It 1 211 .... ,. ,... , . , 100G 060198S . , I . 10 -, k tik TS t\ • \,.).-.. ' 1-. ■ ,...3 '! -... _.-., 0 Z • i- t• -v -, ■ CC, z tz. 411 lib. § 0 )--■-- (6),,.,, -a II= ‘‘ '() '• 0 .._, ' CO l-Ill I. ki,1 ti) 4 O vi '.- . < i ..A , 0 4 1 w ,,,,Tis p‹, ...) '5 co • Cn 0 z o , , 0 qill t ,,..■ 11 V0(3). T--(_) - e ?g7 .—" - C')\ E,‘8(0J )- . -., a.iy. -„, ,o,. • . , _ . Guy Leroy 6828 Torresdale Ave. 1st floor Philadelphia PA 19135 (267)-714-4186 GUY LEROY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • COURT OF COMMON PLEAS • TRIAL DIVISION-CIVIL VS. • HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE • 7 i OF J.P.MORGAN MORTGAGE • Ica t=1 TRUST 2007-AS MORTGAGE PASS THROUGH CERTIFICATES • u� --- �' Defendant .<> - a� AND r ' .. ? ONE WEST BANK,FSB NO 13-1219 and all other persons unknown claiming any : right,title, estate,lien or interest in the real . property described in the complaint adverse : to Plaintiff's ownership,or any cloud to Plaintiff's title • AMENDED ACTION TO QUIET TITLE Defendant(s) • CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon Defendants in this action. Service by first class usps, postage, prepaid was sent to: HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE OF J.P. MORGAN MORTGAGE TRUST 2007-A5 MORTGAGE PASS THROUGH CERTIFICATES 3415 Vision Drive Columbus, OH 43219 DATED:/Z— l' /3 BY: oy • • • U.S,POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL,DOES NOT PROVIDE FOR INSURANCE-POSTMASTER p' A Received From: O a a //-0,,-4/1 ;,^ ^1 m 041 3.-z,-,..9 (4,r,,.5cj.r,(z .:c,re 7 g'� One piece of ordinary mail addressed to: , -o :1-1,_. !..3 C.- S;D.,,,A.,.. 054 v> ,..,..,-,0,.uQschc .r o o G-C',.i/-t-/- Cam, �'1.(` z. � �=Oo 31-i is ,;° s',,,v A(—,,�-r L D IQ—.v (JM cl s , i4 -r32 ( m PS Form 3817,January 2001 U.S. POSTAGE PAIO a. PHILADEELPHIA.PA ., DEG 09,'13 AMOUNT . uratrsnt,z___S nosm`�j�� $1 .20 1000 00019881-15 • 0 ll Z Lt ":.1z u. O a- t,---- 4 6. e U z LL O c)) + a z , to ra a w V zQ 14 d p� o Par \ ' E co w mw 1 • 5' m U Vi �. _ e • `7O E 0.' M o ` tWfl O5 ci 0 co i v ` L co • Q ps 1',. �r aO �� E 0 w m ° a mo a W ¢O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GUY LEROY, Plaintiff; v. HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR JPMORGAN MORTGAGE TRUST, et al. Defendant. CIVIL ACTION NO. 2013-01219 ACTION TO QUIET TITLE STIPULATION OF DISMISSAL STIPULATION OF DISMISSAL IT IS HEREBY STIPULATED AND AGREED by and between counsel for Defendant, HSBC Bank USA, National Association, as Trustee for JPMorgan Mortgage Trust, and counsel for Plaintiff, Guy Leroy, pursuant to agreement, that the above captioned action, along with any counterclaims, cross-claims, third-party claims, interventions, removals and appeals, are voluntarily discontinued with prejudice with each party to bear its own costs. h m s E. Wyle FALZONE&W ER 22 East Third Street Media, PA 19063 Phone: 610.892.8900 twyler@comcast.net Attorney for Plaintiff Dated: 207678) adt C4U/614 Douglas rGush (PA ID No. 209432) MORGAN, LEWIS & BOCKIUS LLP 1701 Market Street Philadelphia, PA 19103 Phone: 215.963.5000 dgush@morganlewis.com Attorney for Defendant Dated:al 9-(49 1 14