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Home My WebLink About13-2083 Supreme. Court-of Peiuis xlt aria Cou, �afCbtnxiion Pleas Z°R? over 11 PY For Prothonotar r 175e On1r: r Cum'berlaad°) j:' County Doi-i NO: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as re uired by law or rules o court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C, JPMORGAN CHASE BANK,NATIONAL RANDALL G.NENNINGER ASSOCIATION TAUNYA S.NENNINGER T I Dollar Amount Requested within arbitration Iimits O Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits 1 Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A -1 Name of Plaintiff/appellant's Attorney:KML Law Groum P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal:Other E mass tort) ❑ Employment dispute: C ❑ Slander/Libel Defamation Discrimination ❑ Employment Dispute: th ❑ Other pyene: er T ❑ Other: I 0 MASS TORT ❑ Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY O Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R C.A 205.5 Updated 11112011 1KML LAW GROUP,P.C. SUITE 5000-BNV MELLON INDEPENDENCE ICE FILED-OFFICE 701 MARKET STREET WriiIE PROTHONOTARY PHILADELPHIA,PA 19106 (866)413-2311 2013 APR 17 FM I WWW.KDU,I,AWGRIJITP.COM ---1 JPMORGAN CHASE BANK,NATIONAL CUMBER LAN "UN I IN THE COURT OF COMMON PLEAS ASSOCIATION PENNSYL ANIA c/o 3415 Vision Drive OF Cumberland COUNTY Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs RANDALL G.NENNINGER ACTION OF MORTGAGE FORECLOSURE TAUNYA S.NENNINGER Mortgagor(s)and Record Owner(s) Ul U 34 East Main Street '3 Plainfield,PA 17081 Voi�GAGF, Defendant(s) 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 ban demandado a usted en la cone. Si usted quiere deferiderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20)digs de plazo a]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 defensas o sus ob eciones a]as demandas en contra de su persona. Sea avisado que si usted no se j p defiende, la corte.toinara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, ]a corte puede decider a favor del demandante y requiere que usted cumpla con todas ]as provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros dereebos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. S1 NO TIENE ABOGADO 0 k" S1 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA 0 LLA M POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA 10 AVERIGUAR DONDE SE PUEDE CONSEGUIR,ASISTENCIA LEGAL. mrvr fly -7 3 Z/ SI LISTED NO PUEDE PAGARLE A UN ABOGADO, F-STA OFICINA PUEDE PROVEEPt INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLF 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 71.7- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.jzov 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 ho://www.ph.fa.or%z/consumers/homeowners/real.q5ax. 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@kmilawgromp.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 111761 FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s)and address(es)of the Defendant(s)i s/are RANDALL G.NENNINGER, 156 Conodoguinet Mobile Est,Newville,PA 17241 and TAUNYA S.NENNINGER, 156 Conodoguinet Mobile Est,Newville,PA 17241,who is/are the mortgagor(s)and record owner(s)of the mortgaged premises hereinafter described. 3. On July 20,2006 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC.D/B/A AMNET MORTGAGE,which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on July 25,2006 as Book 1959 Page 3299. The mortgage has been assigned to: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION by assignment of Mortgage recorded on April 24,2012 as Instrument#201211846. 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 July 01,2011 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..............................I.........................................................$137,762.54 Interest from 06/01/2011 through 01/31/2013 ...........................................$16,072.20 AccruedLate Charges............................................................................7 ...........$145.71 EscrowAdvance.............................................................................................$7,329.29 Property Preservation.........................................................................................$860.00 PropertyInspection............................................................................................$196.00 Suspense........................................................................................................($1,089.70) Reasonable Attorney's Fee.............................................................................$1,450.00 $162,726.04 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 Plaintiff has 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,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$162,726.04, together with interest,costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs,and for the foreclosure and sale of the mortgage property. BY: KML LAW h7YOUP,P.C. Michael McKeever Pa.ID 56129 jay E.Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P.Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION hereby states that he he is Vice President of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. The undersigned understands that this-statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date:O�` �1 �I� ame: Title: Vice President #1.11761FC RANDALL G.NENNINGER and TAUNYA S.NENNINGER Exhibit .A y ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Village of Plainfield,West Pennsboro Township,Cumberland County,Pennsylvania, more particularly bounded and described as follows,to wit: F BEGINNING at a point in the center of the public road leadding from Carlisle to Newville,Route 641,at corner of land now or formerly of Charles F.Nelson and G. Anne Nelson,husband and wife;thence South 68 degrees 42 minutes East 70.65 feet to a point at corner of land now or formerly of J.Lee Ulsh,et ux;thence along land now or r: formerly of J.Lee Ulsh,et ux.,South 20 degrees 47 minutes 30 seconds West 176.14 feet . to a post on land now or formerly of Charles F.Nelson,et ux.;thence along said land now or formerly of Charles F.Nelson,et ux.,North 68 degrees 36 minutes West 70.63 feet to a stake at comer of land conveyed by J.Richard Zimmerman,et ux.,to Charles F. Nelson,et ux.;thence along said latter land now or formerly of Charles F.Nelson,et ux., North 20 degrees 50 minutes East 176.08 feet to a point in the center of said road,the Place of BEGINNING. HAVING thereon erected a frame bungalow and fame shed. TOGETHER with all of the rights of the Grantors herein in,to or over or to the reversion of either of the alleys mentioned in the above described tract of land or shown on the PIan prepared by Noel B. Smith,Registered Surveyor,dated September 1970. t r E..xhibit (B *Exhibit has been redacted to remove all personally identifiable information or non-public information HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM Date: 0211412013 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 intends to foreclose. Specific information about the nature of the default is provided in the attached panes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselins!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 (717) 780-1869)w 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 any 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, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICATION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA. (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO, A REDIMIR SU HIPOTECA. Date: 02/14/2013 HOMEOWNER'S NAME(S): RANDALL G.NENNINGER and TAUNYA S. NENNINGER PROPERTY ADDRESS: 34 East Main Street,Plainfield,PA 17081 LOAN ACCT.NO.: 1980012291 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR AMERICAN MORTGAGE NETWORK,INC. D/B/A AMNET MORTGAGE CURRENT LENDER/SERVICER: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION JPMORGAN CHASE BANK,NA 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. THIS MEETING MUST OCCUR WITHIN(33)DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT",EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT 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. 2 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 temporarily 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. YOUSHOULD FILEA HEMAPAPPLICATIONAS SOONAS POSSIBLE. IF YOU HA YEA MEETING WITHA COUNSEL17VGAGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICA TION W[THPHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE A GAINST YOUR PROPERTY,AS EXPLAINED ABOVE,IN THE SECTION CALLED 'ITEMPORARYSTAY OF FORECLOSURE." YQUIIAVE THE RIGHT TO FILE A HEMAPAPPLICA TIONEVENBEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTINGA FORECLOSUREACTION,BUT IF YOUR APPLICATIONIS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFFS 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.) 3 HOW TO CURE YOUR MORTGAGE DEFAULT(Brine it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 34 East Main Street,Plainfield,PA 17081 IS SERIOUSLY IN DEFAULT because: A.YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: - (a) Monthly payment from 07/01/2011 thru 02/14/2013 (9 mos. at$1,209.23/month) $10,883.07 (I I mos.at$1,575.90/month) $17,334.90 (b) Late charges: $145.71 (c) Other charges;Escrow, Inspec.,NSF Checks: Escrow Advance—$6,694.29 (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $35,057.97 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 $35,057.97,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 p4yable and sent to: CHASE Mail Code: OH4-7384 3415 Vision Drive Columbus, OH 43219 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 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 brings 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 (30)DAY period,you will not be required to Pgy attorney's fees. 4 1. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale, You may do so by pUing the total amount there past due,plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and b y erf orming any other requirements p under the mortgage. 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 four(4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,the amount needed to cure the default 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: CHASE Address: Mail Code: 01-14-7384 3415 Vision Drive Columbus, OH 43219 Phone Number: 800-848-9380 Fax Number: 614-500-4605 Contact Person: Bruno Mejia Email Address: state.programs.intake@jpmehase.com EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs 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 Sheriffs 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 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; 5 v 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 THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD 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. 6 } �V t Comprehensive Housing VU,jNOYLVANIA lid-a4NG pJNA C IAG ENCY Counseling Agencies Agencias de Consejo al Cliente para Vivienda Cumberland County *CCCS of Western PA-York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 t 888.511.2227 www.cccspa. ra Community Action Commission-Capital Region 1514 Derry St Harrisburg PA 17104 717132.9757 www.cactricountv.oro Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing&Redevelopment Authority-Cumberland Cnty 114 N Hanover St;STE 104 Carlisle PA 17013 866.683.5907 1 717.249.0789 www.cehra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 mm.ruraiisc org! aths one pa.htm Pennsylvania Interfaith Community Programs,Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.ara NOTE:Many of the agencies offer workshops at various location sites;call to find a location near you. Report last updated:4/30/2012 9:03:04 AM Page 1 of 1 Eyhibit *Exhibit has been redacted to remove all personally identifiable information or non-public information ` ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE,PA 17013 Instrument Number-201211846 Recorded On 4/24/2012 At 10:19:36 AM Total Pages-3 *Instrument Type-ASSIGNMENT OF MORTGAGE Invoice Number-106701 User ED-MSW *Customer-NATIONWIDE TITLE CLEARING FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES $12.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $10.00 FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $51.50 I Certify this to be recorded in Cumberland County PA RECORDER OI(DIEDS Information denoted by an asterisk may change during the verification process and may not be reflected on this pigO. Prepared By/Re rn To: E.Lance/NTC,2100 Alt.19 North, Palm Harbor,FL 34683 (800)346-9152 /1 Loan#:-2291 �• 003S9B Tax Code/PIN:46-18-1394-104 1 1111((IIIII Illll(IIII IIII IIIII IIIII IIIII IIIII IIIII IIII 1111 ASSIGNMENT OF MORTGAGE -- --Contact JPMORGAN CHASE BANK,N.A.for this instrument 780 Kansas Lane,Suite A,Monroe,LA 71203,telephone#(866)756-8747,which is responsible for receiving payments. FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC. DBA AMNET MORTGAGE, ITS SUCCESSORS AND ASSIGNS (MERS Address: 1901E Voorhees Street,Suite C,Danville, IL 61834) by these presents does convey, grant, sell, assign, transfer and set over the described MORTGAGE therein together with all interest secured thereby, all liens, and any rights due or to become due thereon to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE., LA 71203(866)756-8747,ITS SUCCESSORS OR ASSIGNS,(ASSIGNEE). Said MORTGAGE dated 07/20/2006, in the amount of$146,000.00 made by RANDALL G. NENNINGER AND TAUNYA S. NENNINGER to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC recorded on 07/25/2006, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1959,Page 3299(or Document#n/a) Property more commonly known as:34 EAST MAIN STREET TWP OF WEST PENNSBORO,PLAR*'IELD, PA 17081 Dated on 14-7 2012(MM/DD/YYYY) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR AMERICAN MORTGAGE NETWORK,INC.DBA AMNET MORTGAGE,ITS SUCCESSORS AND ASSIGNS Sandy N.Wells VICE PRESIDENT JPCAS 15902657 —CHASE CJ3640855 N4 MIN 100131020606420758 MERS'PHONE 1-888-679-MFRS FORM5IFRMPAI 1 Ilill{1111{11111 111111111111111111111111 III{lilt *15902657* I 1 Loan#: 2291 STATE OF FLORIDA COUNTY OF PINELLAS The foregoing instrument was acknowledged before me on ( X2012(MMMD/YYYY),by Sandy N. Wells as VICE PRESIDENT for MORTGAGE ELECTRONIC C REGISTRATION SYSTEMS, INC. AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC. DBA AMNET MORTGAGE, ITS SUCCESSORS AND ASSIGNS, who, as such VICE PRESIDENT being authorized to do so, executed the foregoing instrument f the urposes therein contained.He/she/they is(are)personally known to me. AM•, Miranda Avila I Notary Public Spate of Florida Miranda Avila '�,V My Commission#EE 019063 Notary Public-State of FLORIDA Expires August 22,2014 Commission expires:08/22/2014 Assignment of Mortgage from: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC. DBA AMNET MORTGAGE, ITS SUCCESSORS AND ASSIGNS (VIERS Address:1901 E Voorhees Street,Suite C,Danville,IL 61834) to: JPmORGAN MC 000,MONNRROEE,LLAA71203 NATIONAL(866)756.87475 ITS SUCCESSORS OR ASSIGNS(ASSIGNEE)� LANE, Mortgagor:RANDALL G.NENNINGER AND TAUNYA S.NENNINGER When Recorded Return To: JPMorgan Chase Bank,NA C/O NTC 2100 Alt. 19 North Palm Harbor,FL 34683 All that certain lot or piece of ground situated in Mortgage Premise:34 EAST MAIN STREET TWP OF WEST PENNSBORO PLAINFIELD,PA 17081 CUMBERLAND (Borough or Township,if stated),Commonwealth of Pennsylvania. Being more particularly described in said mortgage. I,Sandy N.Wells,do certify that the precise address of the within named assignee is: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,WHOSE ADDRESS IS 700 KANSAS LANE,MC 8000,MONROE,LA 71203(866)756-8747,ITS SUCCESSORS OR ASSIGNS,(ASSIGNEE) i Alar By: Sandy . fills -VICE PRESIDENT *15902657 JPCAS 15902657 --CHASE CJ3640855 N4 MIN 100131020606420758 MERS PHONE 1-888-679-MERS FORM5IFRMPAI !111!11 1!1!!111!1 lllll IllII(IIII Iilli IlIII IIII IIII *15902657* s . C IN THE COURT OF COMMON PLEAS Ol, _;l ,..4 CUMBERLAND COUNTY,PENNSYLV4W �- rTI JPMORGAN CHASE BAND.,NATIONAL ASSOCIATION ° Plaintiff Case No. ? vs. ,�U rl �t CO RANDALL G.NENNINGER TAUNYA S.NENNINGER Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitte (Signature of Counsel laintiff) 4/15/2013 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance,your lender must consider your circumstances to determine.possible options while working with your Please provide the following information to the best of your knowledge: Ct.jST0MER/P11l.,N'lAI?Y APPLICANT Borrower name(s): - Property Address: City: -- —State:—_ _ Zip: Is the property for sale? Yes[J- No (J Listing date: _ _ ._-- Price: Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): City: State`—Zip: Phone Numbers: Home: Office: Cell: Other° Email: #of people in household: How long? - Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Cell: Other: E-mail: - - #ofpeople in household: How long? -- —_ - First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: Included Taxes&Inssurance: Date of Last Payment: Primary Rea,son for Default: Is the loan in Bankruptcy? Yes No If yes,provide names,location of court,case number&attorney: Assets Amount Owe d0wed: Va.iue: Hoene: $ $ Other Real Estate: $ — --- $--- Retirement Funds: $ --- Investrnents: $ $ Checking: $ - Savings: $ $ Other: $� $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: `Fear; Amount owed: Value: Other transportation(automobiles,boats,mgtoreycles): Model: - Year Amount owed: _- _ Value Monthly Income Name of Employers: 1. 2. 3. .Additional Income Description(not wages): 1. monthly amount: „ - 2, monthly amount: Borrower Pay Days: ------ -----._.._..__.. .. Co-Borrower Pay Days: ,Monthly Expenses:,(Please only include expenses you are currently paying) EXPENSE AMOUNT - EXPENSE AMOUNT Mo a Food 2no M e Utilities Car PLYmSngq Condo/N!! .Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop.payment Install.Loan Payment - ... Cable TV Child Sup p2rt/Alirn. Spending Mone Ua !Child Caret!pit, Other Ex Lenses Amount Available for Monthly Mortgage Payments aased on Incomes&Expenses: Have you been working with a Housing Counseling Agency? Yes EJ No If yes,please provide the following information: Counseling Agency: Counselor. Phorte.(Oflice). Fax: Email; Have you made application for Homeowners Emergency Mortgage Assistance Program ( REMAP)assistance? Yes-Ej No 0 If yes,please indicate the status Of the application: Have you had any prior negotiations with your tender or lender's loan servicing company to resolve your delinquency? Yes M No 11 If yes,please indicate the status of those negotiations: Please provide the following information,if know,regarding your lender or leader's loan servicing company: Lender's Contact(Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATU N Itwe, authorize the above named to use/refer this information to my londerlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/Wo understand that Uwe am/are under no obligation to use the services provided by the above rimned Borro;;�er Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past2 bankstatements Proof of any expected income for the lost 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing 4groe�w nt{if property is current.ly on the mark SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED-OFF 11UF Sheriff l! '+ ! ' ; ��av'(tx�at r��d Jody S Smith 7013 PAY 13 AM 10- 337 Chief Deputy Richard W Stewart `~ ' " CUMSEPUND SOWN j Y Solicitor OFF if;GOF THE SVERIFF PENNSYLVANIA JPMorgan Chase Bank, National Association vs. Case Number Randall G Nenninger(et al.) 2013-2083 SHERIFF'S RETURN OF SERVICE 05/03/2013 08:24 PM -Sheriff Ronny R. Anderson, being duly sworn according to law, attempted service to the Defendant, to wit: Randall G Nenninger at 34 E. Main Street, West Pennsboro, Plainfield, PA 17081.The address was found to be vacant. 05/03/2013 08:24 PM- Sheriff Ronny R.Anderson, being duly sworn according to law, attempted service to the Defendant, to wit: Taunya S Nenninger at 34 E. Main Street, West Pennsboro, Plainfield, PA 17081. The address was found to be vacant. 05/03/2013 09:01 PM-Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Randall G Nenninger at 156 Conodoguinet Mobile Est, Newville, PA 17241. Deputies were advised by the defendant's that they filed bankruptcy, Case#10-06167. S TSHAL , DEPUTY 05/03/2013 09:07 PM- Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Randall Nenninger, Husband of defendant, who accepted as"Adult Person in Charge"for Taunya S Nenninger at 156 Conodoguinet Mobile Est., Newville, PA 17241. Deputies were advised by the defendant's that they filed bankruptcy, Case #10-06167. SWAWW-GdTSHAILL, DEPUTY SHERIFF COST: $64.34 SO ANSWERS, KZX May 06, 2013 RONIS�S'R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 3415 Vision Drive r, Columbus,OH 43219 C= 3 Plaintiff No. 13-2083 1 D-- VS. 1e � RANDALL G.NENNINGER CV J r';r TAUNYA S.NENNINGER �' i (Mortgagor(s)and Record Owner(s)) 34 East Main Street Plainfield,PA 17081 �~ C-) Defendant(s) C 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 RANDALL G.NENNINGER and TAUNYA S.NENNINGER by default for want of an Answer. Assess damages as follows: $162,726.04 Debt Interest from 2/1/2013 to Date of Sale per diem at$26.42 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 delivered to the pgwlyagainst whom judgment is to be entered and to his attorney of record,if any,after the default occ nd at least to days for to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.237.1 By: KML LAW OUP,P.C. Michael M eever Pa.ID 5612 _Jay E.Kid�tz Pa.ID 26769 Lisa Lee Pa.ID 78020 Thistma Murtha Pa.ID 61858 hom Fein Pa.a.ID 82628 �1�// <^ Q/Thomas Puleo Pa.ID 27615 �J ((,.7�r � _Joshua I.Goldman Pa.205047 �` _Jill P.Jenkins Pa.ID 306588 (��j g _Andrew F.Gomall Pa.ID 92382 v/ Attorneys for Plaintiff P / R Ott AND NOW �,� CZ1 3 ,Judgment is entered in favor o�J(ht M4, E JPMORGAN CHASE BANK,NATIONAL ASSOCIATION and against RANDALL G.NENNINGER and TAUNYA S. NENNINGER by default for want of an Answer and damages assessed in the sumo 162,7 04 as e above certification. 1) R. Prot ota Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13-2083 vs. RANDALL G.NENNINGER TAUNYA S.NENNINGER (Mortgagors and Record Owner(s)) 34 East Main Street Plainfield,PA 17081 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 I Courthouse Square Carlisle,PA 17013 Prothonotary By: 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor UFFCE OF Tkzlz F- JPMorgan Chase Bank, National Association v Case Number S. Randall G Nenninger(et al,} 2013-2083 SHERIFF'S RETURN OF SERVICE 05/0312013 08:24 PM-Sheriff Ronny R.Anderson,being duty sworn according to law,attempted service to the Defendant,to wit: Randall G Nenninger at 34 E.Main Street,West Pennsboro, Plainfield, PA 17081.The address was found to be vacant. 05/0312013 08:24 PM-Sheriff Ronny R.Anderson,being duly sworn according to law,attempted service to the Defendant,to wit:Taunya S Nenninger at 34 E. Main Street, West Pennsboro, Plainfield, PA 17081.The address was found to be vacant. 05103/2093 09:01 PM-Deputy Shawn Gutshall, being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Randall G Nenninger at 956 Conodoguinet Mobile Est, Newville, PA 17241. Deputies were_advised by the defendant's that they filed bankruptcy,Case#10-06167, d . S TSHAL , DEPUTY 05/0312013 09:07 PM-Deputy Shawn Gutshall,being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint.in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Randall Nenninger,Husband of defendant,who accepted as"Adult Person in Charge"for Taunya S Nenninger at 156 Conodoguinet Mobile Est., Newville, PA 17241. Deputies were advised by the defendant's that they filed bankruptcy, Case #10-06167. - c SYAOACG&SHAILL, IYffPUTY SHERIFF COST:$64.34 SO ANSWERS, May 06,2013 RbNW R ANDERSON,SHERIFF (Cy Cnun:-Ku;(e She�Y.,ToRoseP,,In,. 111761FC 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY DATE OF THIS NOTICE_,: July 3,2013 TO: RANDALL G NENNINGER 34 East Main Street Plainfield,PA 17081 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION In the Court of Common Pleas c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff VS' CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 34 East Main Street Plainfield,PA 17081 No. 13-2083 Defendant(s) TO: RANDALL G NENNINGER 34 East Main Street Plainfield,PA 17081 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TI-IE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH 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 LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LFGAI.SF,RVICF,S INC 8 ILvine Row Carlisle,PA 17013 717-243-9400 / By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristine Murtha Pa. ID 61858 D vid Fein Pa.ID 82628 lyk L.Otlazian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff 111761FC 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY DATE OF TBTS NOTICE: July 3,2013 TO: TAUNYA S NENNINGER 34 East Main Street Plainfield,PA 17081 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Common Pleas c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff vs. CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 34 East Main Street Plainfield,PA 17081 No. 13-2083 Defendant(s) TO: TAUNYA S NENNINGER 34 East Main Street Plainfield,PA 17081 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE nIE OFFICE SET FORTH BELOW. TIIIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO I-ERE 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 13AR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA17013 717-243-9400 By: KML LAW GUOUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ED 78020 Kristins Murtha Pa.ID 61858 vid Fein Pa.ID 82628 Alyk L.Oflazian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff 111761FC 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 DEIST.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY DATE OF THIS NOTICE: July 3,2013 TO: RANDALL G.NENNINGER 156 Conodoguinet mobile Est, Newville,PA 17241 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Common Pleas c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff VS. CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 34 East Main Street Plainfield,PA 17081 No. 13-2083 Defendants) TO: RANDALL G.NENNINGER 156 Conodoguinet'mobile Est, Ncwville,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) [JAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TARE 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. CUMBERLAND COUNTY 13AR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 l By: KML LAW G OUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 avid Fein Pa.ID 82628 A1yk L.Oflazian Pa.ID 312912 215-627.1322 Attorneys for Plaintiff 111761FC 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY DATE OF THIS NOTICE: July 3,2013 TO: TAUNYA S.NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Common Pleas c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff VS. CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 34 East Main Street Plainfield,PA 17081 No. 13-2083 Defendant(s) TO: TAUNVA S.NENNINGER 156 Conodoguinct Mobile Est Newvillc,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WIT'HOUT A BEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER- IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COMMAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Raw Carlisle,PA 17013 717-243-9400 By: KmLrAw GRbup,P.C. Michael McKeever Pa.10D 56129 Lisa Lee Pa.ED 78020 -Kpistina Murtha Pa.ID 61858 z6avid Fein Pa.ID 82628 �Alyk L.Oflazian Pa.ID 312912 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff VS. RANDALL G.NENNINGER NO.13-2083 TALTNYA S.NENNINGER 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.miUappj/scra/scraHome.do) for the following individual(s): RANDALL G. NENNINGER, has a last known residence of 156 Conodoguinet Mobile Est, Newville, PA 17241. The following information was used to search the DMDC(check all that apply): • Last Name • First Name • 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.4904 relating to unswom falsification to authorities. Date 7 By: KNY LAW GROUY,P.C. Michael Mc ever Pa. ID 56129 -Lisa Lee Pa. ID 78020 Krishna Murtha Pa.ID 61858 /,David Fein Pa.113 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 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Jul-18-2013 11:02:58 SCRA 3,0 I stag Report want to Sery cemembers Civil Rclief Act. Last Name: NENNINGER First Name: RANDALL Middle Name: G. Active Duty Status As Of: Jul-18-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date status Service Component NA NA ,.. , - No NA This response reffects"the indivlhluais'active duty status based on the Active Duty Status Date i t Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA '" - _ No" NA t This response reflects Where the individual left aelive.duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ;�� 's- "No - NA This response reflects whether the individual or his/h a�r unit has received earty 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. �w 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 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 Nary 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: L34F137D5072230 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff vs. RANDALL G.NENNINGER NO. 13-2083 TAUNYA S.NENNINGER 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 (hitps://www.dmde.osd.mi!Lappj/scra/scraHome.do) for the following individual(s): TAUNYA S. NENNINGER, has a last known residence of 156 Conodoguinet Mobile Est, Newville, PA 17241. 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. 4904 relating to unsworn falsification to authorities. r' Date �/� By: KML L GR 6 up--, eu hael McKeever 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 -A avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall 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:Jul-18-2013 11,06:51 SCRA 10 Status Pvepoft Pursuant to Servicernembers Civil Relief Act Last Name: NENNINGER First Name: TAUNYA Middle Name: S. Active Duty Status As Of: Jul-18-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date status Service Component NA NA No. NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date — 1-0--Notification End Date Status Service Component NA NA No NA This response reflects whether the Individual or bis/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 1A 4IrjL - *A��_ 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.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 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: N33373ADQ073KCO KML Law Group, P.C. Suite 5000–BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER (Mortgagor(s)and Record owner(s)) ACTION OF MORTGAGE FORECLOSURE 34 East Main Street Plainfield,PA 17081 Defendant(s) No. 13-2083 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,and against RANDALL G.NENNINGER and TAUNYA S.NENNINGER for failure t file an Answ e above action within(20) days from the date of service of the Complaint,in the sum of$162,726 By: KML ' GROUP C. Mich 9I 1 McKeever a.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 Tavid Fein Pa.ID 82628 homas Puleo Pa.ID 27615 Joshua 1.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 c/o 3415 Vision Drive Columbus,OH 43219 and that the name(s)and last known address(es)of the Defendant(s)is/are RANDAL NNINGE 6 Conodoguinet Mobile Est Newville,PA 17241 and TAUNYA S.NENNINGER, 156 ConoAe:t e Est New ille, 17241; By: KML P,P Mich a. 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 —Kristi-na Murtha Pa. ID 61858 avid Fein Pa.ID 82628 _JZThomas 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 $137,762.54 Interest from 06/01/2011 through $16,072.20 01/31/2013 Reasonable Attorney's Fee $1,450.00 Late Charges $145.71 Escrow Advance $7,329.29 Property Preservation $860.00 Property Inspection $196.00 Suspense ($1,089.70) $162,726.04 By: LAW GRO ,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 �David Fein Pa.ID 82628 homas Puleo Pa.ID 27615 Joshua L Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gomall Pa.ID 92382 Attorneys for Plaintiff AND NOW,this day of ,2013 damages are assessed as above. Pro Prothy 13-2083/111761FC 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 c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 Plaintiff of Cumberland County vs. CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 34 East Main Street Plainfield,PA 17081 No. 13-2083 Defendant(s) tt-- rJ r PRAECIEPE FOR WRIT OF EXECUTION > C) 77 TO THE PROTHONOTARY: (10 Issue Writ of Execution in the above matter: Amount Due $162,726.04 Interest from 2/1/2013 to Date of Sale per them at$26.42 (Costs to be added) Z By:_ Kp4j/LAW GROpf,P.C. --Nf1'c-hae1 McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 0? Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 9(avid Fein Pa.ID 82628 /rhomas Puleo Pa.ID 27615 1 Joshua I.Goldman Pa.205047 7,� Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 XA�t&eys for Plaintiff Pj soo-, 9 ?clny J�5uec No. 13-2083 IN THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK,NATIONAL ASSOCIATION vs. RANDALL G.NENNINGER and TAUNYA S.NENNINGER (Mortgagor(s)and Record Owner(s)) 34 East Main Street Plainfield,PA 17081 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Village of Plainfield,West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point in the center of the public road leading from Carlisle to Newville, Route 641,at corner of land now or formerly of Charles F. Nelson and G.Anne Nelson, husband and wife;thence South 68 degrees 42 minutes East 70.65 feet to a point at corner of land now or formerly of J. Lee Ulsh, et ux;thence along land now or formerly of J. Lee Ulsh,et ux.,South 20 degrees 47 minutes 30 seconds West 176.14 feet to a post on land now or formerly of Charles F. Nelson,et ux.;thence along said land now or formerly of Charles F. Nelson,et ux., North 68 degrees 36 minutes West 70.63 feet to a stake at corner of land conveyed by J. Richard Zimmerman, et ux.,to Charles F. Nelson,et ux.;thence along said latter land now or formerly of Charles F. Nelson,et ux., North 20 degrees 50 minutes East 176.08 feet to a point in the center of said road,the Place of BEGINNING. HAVING thereon erected a frame bungalow and frame shed. TOGETHER with all of the rights of the Grantors herein in,to or over or to the reversion of either of the alleys mentioned in the above described tract of land or shown on the Plan prepared by Noel B.Smith, Registered Surveyor,dated September 1970. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY WEST PENNSBORO TOWNSHIP BEING PREMISES: 34 East Main Street,Plainfield,PA, 17081 SOLD as the property of Randall G. Nenninger and Taunya S. Nenninger, husband and wife TAX PARCEL#46-18-1394-104 KML Law Group,P.C. Suite 5000=BNY Independence Center 701 Market Street Philadelphia,PA 19106 U THE ='f i3 r !C Pd flI 'r 215-627-1322 Attorney for Plaintiff 70113 JUL 22 AM 11: 3 l JPMORGAN CHASE BANK,NATIONAL C D-f E E P L AP D COUNTY ASSOCIATION PENNSYVANIA IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff VS. CIVIL ACTION-LAW RANDALL G.NENNINGER TAUNYA S.NENNINGER (Mortgagor(s)and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 34 East Main Street Plainfield,PA 17081 Defendant(s) No. 13-2083 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 34 East Main Street Plainfield,PA 17081 1.Name and address of Owner(s)or Reputed Owner(s): RANDALL G.NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 TAUNYA S.NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 2.Name and address of Defendant(s)in the judgment: RANDALL G.NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 TAUNYA S.NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 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 4.Name and address of the last recorded holder of every mortgage of record: 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 34 East Main Street Plainfield,PA 17081 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: '� 4By: LAW G UP,P.C. Michael McKg6ver Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 Tavid Fein Pa.ID 82628 homas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Attorneys for Plaintiff 13-2083 KML Law Group,P.C. Suite 5000-BNY Independence Center -- -- '� '`°rv' �t -; 701 Market Street U~ 1. `" P R 0 T H Q N1 G �'3 C . Philadelphia,PA 19106 2813 JUI 22 Ari 11: 3 1 (215)627-1322 Attorney for Plaintiff �,t;.. ly : AHO COMITY JPMORGAN CHASE BANK,NATIONAL P F N N S Y LVA P1,{A ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. RANDALL G.NENNINGER ACTION OF MORTGAGE TAUNYA S.NENNINGER FORECLOSURE Mortgagor(s)and Record Owner(s) 34 East Main Street Plainfield,PA 17081 Docket No. 13-2083 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NENNINGER,RANDALL G. RANDALL G. NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 Your house at 34 East Main Street,Plainfield,PA 17081 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$162,726.04 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 13-2083 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htip://www.philadelphiafed.or,wforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-2083 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/bomeowners/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 gkmllawgroW.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 111761FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-2083 � t KML Law Group,P.C. Suite 5000-BNY Independence Center �` �'- t 1° 1 H 0- 701 Market Street Philadelphia,PA 19106 1013 JUL. 2 2 AM I 1 : 3' 1 (215)627-1322 CfjMBERLANn COUNTY Attorney for Plaintiff A NJ n Y ... JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff CIVIL ACTION-LAW VS. RANDALL G.NENNINGER ACTION OF MORTGAGE TAUNYA S.NENNINGER FORECLOSURE Mortgagor(s)and Record Owner(s) 34 East Main Street Plainfield, PA 17081 Docket No. 13-2083 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NENNINGER,TAUNYA S. TAUNYA S. NENNINGER 156 Conodoguinet Mobile Est Newville,PA 17241 Your house at 34 East Main Street,Plainfield,PA 17081 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$162,726.04 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. w 13-2083 4 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: hqp://www.philadelphiafed.orWforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 S rt� 13-2083 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/bomeowners/real.as x. 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 gkmllawgroup.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 111761FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2083 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff(s) From RANDALL G.NENNINGER,TAUNYA S.NENNINGER (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: $162,726.04 L.L.: $.50 Interest FROM 2/1/2013 TO DATE OF SALE PER DIEM AT$26.42 Atty's Comm: Due Frothy:$2.25 Atty Paid: $213.09 Other Costs: Plaintiff Paid: Date: 7/22/13 D.Buell.P thonotai /bonotary .(Sea]) y By: Deputy REQUESTING PARTY: Name'r THOMAS PULEO,ESQUIRE Address:'XML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone:215-627-1322 Supreme Court ID No.27615 KML LAW GROUP,P.C. 11 1761F Suite 5000 CF: 04/17/2013 BNY Mellon Independence Center � ' k SD: 12/04/2013 701 Market Street ' " "`' '''`'' $162,726.04 Philadelphia,PA 19106-1532x4, `' 215-627-1322 Ni 0 Attorney for Plaintiff I`A eta i-: fl.0 U H T JPMORGAN CHASE BANK,NATIONAL ! YI.VANIM THE COURT OF COMMON PLEAS ASSOCIATION c/o 3415 Vision Drive of Cumberland County Columbus, OH 43219 Plaintiff CIVIL ACTION—LAW VS. ACTION OF MORTGAGE FORECLOSURE RANDALL G.NENNINGER TAUNYA S.NENNINGER Term Mortgagor(s)and No. 13-2083 Record Owner(s) 34 East Main Street Plainfield,PA 17081 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Veronica Cosine, 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 Cosine Legal Assistant co. O �ty m C4 W N --1 Q 14 CAA W coo v3wn Q 4 ° G r e IL a . ... ' J °ci'8 m U z (n d = Z is m ycaEc E Co y v-- 5 N � d'v= icw 9w as m N UUO m 0 E Q LL V c Qc o o ao U) c _ m d Z y IL '.� Z W c c d FW-c a o m t m c d c O D O �[ g °d R w CL d w W N E y Fes- i U U 2 ° � p [3 O :)W U a z E M ui 0�g �jj Q U- 0:9 LO > u t H O Q Co O U p o.� o Zcn @ W w n Q o W Z_ orn `m wZ o 0 W 7w co c � � Z oC)a0 ami m a u Uj Dz Q a° rn U 06 m d a n Z.? N . ,� p N E p a N a Z co W °' ~ E z Q c� y d Q on L U Z U)Q _ ti Cry v �YCoWil ay Q U Y J(M o o co LL -i -°c O WLn �� r Q W LO n D (O Q mm Qp E O ti a -ow Za r Q J I- J O v (4 �- w Z�U)0 d- r N C9 d7 CO N CO -j a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , 9,V to of lrutbr+/��d Jody S Smith T Chief Deputy < , Richard W Stewart t=-j Solicitor OFFICE OF THE SµERr-F i JPMorgan Chase Bank, National Association Case Number vs. Randall G Nenninger(et al_) 2013-2083 SHERIFF'S RETURN OF SERVICE 09/20/2013 03:48 PM -Deputy Ryan Burgett, 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 34 East Main Street, West Pennsboro-Township, Plainfield, PA 17081, Cumberland County. 09/23/2013 02:17 PM-Deputy Jason Kinsler, 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 Taunya Nenninger,Wife, who accepted as"Adult Person in Charge"for Randall G Nenninger at 156 Conodoguinet Mobile Est, Newville, PA 17241, Cumberland County. 09/23/2013 02:17 PM-Deputy Jason Kinsler, 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: Taunya S Nenninger at 156 Conodoguinet Mobile Est., Newville, PA 17241,Cumberland County. SHERIFF COST: $984.55 SO ANSWERS, October 24,2013 RbNtZY R ANDERSON, SHERIFF i ' i i I I I (r)Countysuite Sheritf,Teleocoft,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 c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW VS. RANDALL G.NENNINGER ACTION OF MORTGAGE FORECLOSURE TAUNYA S.NENNINGER Mortgagor(s)and Record Owner(s) Term No. 13-2083 34 East Main Street Plainfield,PA 17081 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,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: 34 East Main Street Plainfield,PA 17081 1.Name and address of Owner(s)or Reputed Owner(s): RANDALL G.NENNINGER 156 Conodoguinet Mobile Est Newville, PA 17241 TAUNYA S.NENNINGER 156 Conodoguinet Mobile Est Newville, PA 17241 2.Name and address of Defendant(s)in the judgment: RANDALL G.NENNINGER 156 Conodoguinet Mobile Est Newville, PA 17241 TAUNYA S.NENNINGER 156 Conodoguinet Mobile Est Newville, PA 17241 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 4.Name and address of the last recorded holder of every mortgage of record: 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 34 East Main Street Plainfield, PA 17081 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 /> ML Law Group, P.C. BY: Veronica Cosine Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Ander`so4 �J - Sheriff ,.v1 ;� Jody S Smith Chief Deputy 2. j 4 Richard W Stewart r =¢ :t LA D x+r,, Solicitor f rric.E OF; u4F iFF PENNSYLVANIA JPMorgan Chase Bank, National Association Case Number vs. 2013-2083 Randall G Nenninger(et al.) SHERIFF'S RETURN OF SERVICE 09/20/2013 03:48 PM - Deputy Ryan Burgett, 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 34 East Main Street, West Pennsboro-Township, Plainfield, PA 17081, Cumberland County. 09/23/2013 02:17 PM -Deputy Jason Kinsler, 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 Taunya Nenninger, Wife, who accepted as"Adult Person in Charge"for Randall G Nenninger at 156 Conodoguinet Mobile Est, Newville, PA 17241, Cumberland County. 09/23/2013 02:17 PM - Deputy Jason Kinsler, 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: Taunya S Nenninger at 156 Conodoguinet Mobile Est., Newville, PA 17241, Cumberland County. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Michel McKeever, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $989.89 SO ANSWERS, January 23, 2014 RONNY R ANDERSON, SHERIFF ex P,1 . ace -R. _ foot - • a0 cif—77G Atir 3 o a '0/ Jou:,ySj t, fl Tel,csoft.Ire. On August 23, 2013 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, Known and numbered as, 34 East Main Street, Plainfield, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 23, 2013 By: Real Estate Coordinator _ r4"7 • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No 2013-2083 Civil Term IMPROVEMENTS consist of a residential dwelling. JPMORGAN CHASE BANK, MUNICIPALITY WEST PENNS- NATIONAL ASSOCIATION BORO TOWNSHIP. BEING PREMISES:34 East Main vs. Street,Plainfield,PA, 17081. RANDALL G.NENNINGER, SOLD as the property of Randall Taunya S.Nenninger G. Nenninger and Taunya S. Nen- Atty.:Michael McKeever ninger,husband and wife. ALL THAT CERTAIN tract of land TAX PARCEL#46-18-1394-104. with the improvements thereon erect- ed situate in the Village of Plainfield, West Pennsboro Township, Cum- berland County,Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at a point in the center of the public road leading from Carlisle to Newville,Route 641, at corner of land now or formerly of Charles F. Nelson and G. Anne Nelson, husband and wife; thence South 68 degrees 42 minutes East 70.65 feet to a point at corner of land now or formerly of J.Lee Ulsh,et ux; thence along land now or formerly of J.Lee UIsh,et ux.,South 20 degrees 47 minutes 30 seconds West 176.14 feet to a post on land now or formerly of Charles F. Nelson, et ux.; thence along said land now or formerly of Charles F. Nelson, et ux., North 68 degrees 36 minutes West 70.63 feet to a stake at corner of land conveyed by J. Richard Zimmerman, et ux., to Charles F. Nelson, et ux.; thence along said latter land now or formerly of Charles F.Nelson,et ux.,North 20 degrees 50 minutes East 176.08 feet to a point in the center of said road, the Place of BEGINNING. HAVING thereon erected a frame bungalow and frame shed. TOGETHER with all of the rights of the Grantors herein in,to or over or to the reversion of either of the alleys mentioned in the above de- scribed tract of land or shown on the Plan prepared by Noel B.Smith, Registered Surveyor, dated Septem- ber 1970. 90 • 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. s f 0 a Marie Coyne, E itor U SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 . 4 / i / 1,_ '// . Notary U-,., NOTARIAL SEAL DEBNAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy 1it atnotiXtws 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. This ad ran on the date(s)shown below: Ink 10/13/13 amp 11110401 Illelftever Z. 10/20/13 ALL MAT CERTAIN land / 10/27/13 with the thereon erected situate in the Village of.Plainfield, West — / / Penusbos° Cumberland County, Pennsylvania,more Poly bounded and . ° ° . . • • described BEGINNING asfolllowws,to wit: public at a point lathe center of the adingfrom Carlisle toNewville Sworn to a d subscribed before me this 11 day of November, 2013 A.D. Route 641,at corner of land now or formed; of Charles F Nelson and G.Anne Nelson, /�n ' / y husband and wife;thence South 68 degrees :A 42 minutes East 7,265feettoa point atcomer • •---' �'- .1A �.1 L l c of land now orformerly ofJ.Lee Uhh,et us; No I fir u bl is ' P thence along land now or formerly of J.Lee -UIs6,et ux,South 20 degrees 47 minutes 30 s seconds West 176°14 feet to a post on land now or formerly Of Charles F Nelson,et ux; COMMONWEALTH OF PENNSYLVANIA thence along sax"land now or formerly of Charles F Nelson,etwc,North 68 degrees 36 iJneTIIIi minutes West 70.63 feet to a stake at coof Holly Lyn n±' C land harlesF J Rtdtatd 7iemnerman'et l sngtn±,vy Neon,et ua;theta aln Y Commist�n 16 said latter land now orforme ofChade$F MEMBER,PENNSILVA ASSxnt`ih(,�NOTARIES Nelson,et ter;-Manta 20 degrees*minutes East 1761X feet to a point i we allter of said road,the Place of BEGINNING. HAVING thereon err cted a frame bungalow ....1 a.......L_• COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer,Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 22nd day of July, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2083, at the suit of JPMorgan Chase Bank,NA against Randall G.Nenninger and Taunya S.Nenninger is duly recorded as Instrument Number 201404953. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /0 day of farce , A.D. ,0/`1 ) 12A/Z:Lig Recorder'of Deeds Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018