HomeMy WebLinkAbout13-2639 'Supreme Court of Pennsylvania
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The information collected on this form is used solely for court administration purposes. This form does not
Supplement or replace the filing and service of leadin s or other papers as required b law or rules" of court.
3 a Commencement of Action:
#�� ® Complaint ❑ Writ of Summons 0 Petition
❑ Transfer from another Jurisdiction ❑ Declaration of Taking
EN# Lead Plaintiff Name: Lead Defendant's Name:
h JPMORGAN CHASE BANK, NATIONAL NANCY ELLA WALKER
C ASSOCIATION
Dollar Amount Requested within arbitration limits
Are money Damages requested ?: ❑ Yes . - ®No (Check one) X outside arbitration limits
3 Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO
1
Name of Plaintiff/appellant's Attorney: KML Law Group, P.C.
❑ Check here if you are a Self-Represented (Pro Se Litigant HU
Nature of the Case Place an "X" to the left of the ONE case catego ely desc
ry that most accuratribe
s your
PRIMARY CASE If you are making more than one type of claim, check the one that
consider most important
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL
3 ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution' ❑Debt Collection: Credit Card 11 Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Zoning Board
Product Liability (does not include ❑Statutory Appeal: Other
�i `... ❑ Employment dispute:
mass tort)
❑ Slander/Libel Defamation Discrimination
El Other ❑ Employment Dispute: Other
❑ Other:
0' - g` MASS TORT ❑Other
❑ Asbestos
1 AE c ' ❑ Tobacco
❑Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant
❑ Ejectment ❑ Common Law /Statutory
❑Toxic Waste .❑ Eminent Domain/Condemnation Arbitration
❑ Other
Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑ Mandamus
® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order
dL
4 ' x
❑ Dental ❑Partition ❑ Quo Warranto
j '` ❑Legal ❑ Quiet title ❑ Replevin
❑ Medical
�� ❑ Other Professional: ❑ Other ❑ Other
R.
Pa.R.C.P. 205.5 Updated 1/1/2011
KML LAW GROUP, P.C. r
SUITE 5000 - BNY MELLON INDEPENDENCE CENTER F' { LED- Ctt 0 F fl � � T
701 MARKET STREET C �� E p r t3 F 1
PHILADELPHIA, PA 19106
(866) 413- 2311,�'��
JPMORGAN CHASE BANK, NATIONAL 4 CO E COURT OF COMMON PLEAS
ASSOCIATION] ( L'}�t�l ¢�
c/o 3415 Vision Drive OF Cumberland COUNTY
Columbus, OH 43219
Plaintiff CIVIL ACTION - LAW
VS.
NANCY ELLA WALKER ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s) and Record Owner(s) q
219 Marion Avenue ( 014;1
Carlisle, PA 17013 CIVIL, ANON: MORTGAGE
Defendant(s) FORECLOSM
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
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LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES 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 AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243 -9400.
2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling.
3). Visit HUD' S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aWx
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.Dhiladelphiafed.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 homeretentiongkmllawaroup.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 1168911
Para informacion 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) is /are NANCY ELLA WALKER, 219 Marion Avenue,
Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises
hereinafter described. Max Elsworth Walker died on February 18, 2008 by operation of law title vests
solely in Nancy Ella Walker and Max Elsworth Walker is hereby released of liability pursuant to
Pa.R.C.P 1144.
3. On October 05, 2007 mortgagor(s) made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR M &T BANK, which mortgage is recorded in the Office of the Recorder of Deeds of
Cumberland County on October 15, 2007 as INSTRUMENT # 200739559. The mortgage has been
assigned to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION by assignment of Mortgage
recorded on October 15, 2012 as Instrument # 201231604. Plaintiff is the real party in interest pursuant
to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public
record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure
1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those
documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ( "Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for June 01, 2012 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 April 5, 2013:
PrincipalBalance ........................................................... ............................... $73,635.06
Interest from 05/01/2012 through 03/31/2013 ....................... ......................$4,471.83
Accrued Late Charges .................................. ............................... .........................$52.86
EscrowAdvance ........................................ ............................... ......................$2,144.34
PropertyInspections .................................... ............................... ........................$126.00
Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00
$82,080.09
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 " 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 $82,080.09,
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 UP P.C.
Michaetic er 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
i
2) 6 , hereby states that he she Vice President is 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 unswom falsification to authorities.
Date: Oq
Name:
Title:
Vice President
J Q �arSG COGS -� C3Ghk, N R.
#116891FC
NANCY ELLA WALKER
E.�h i 6 i t A
t
ALL,that certain tract of land with the improvements thereon erected
i
situate in North. Middleton Township, Cumberland County, Pennsylvania,
bounded and described as follows:
i
BEGINNING. at a point on the Northerly line of Marion Road at a stake
which is 288 feet East from the Northeast intersection of Maplewood
Road and Marion Road; thence by the Easterly line of lands now or formerly
of Meek, North 18 degrees 30 minutes East 140 feet to a point at a stake;
thence by lands now or formerly of Bucher, South 71 degrees 30 minutes
East 85 feet to a point at a.stake; thence by lands now or formerly of,
Bucher, South 18 degrees 30 minutes West 140 feet to a point on the said
Northerly line of Marion Road; thence by the said line of Marion Road,
North 71 degrees 30 minutes West 85 feet to a point at a stake, the
Place of BEaINNINa-
BEING Improved with a one story Frame dwelling known as No. 219
Marlon Road-
EXHIBIT "A"
i
Ey (13
*Exhibit has been redacted to remove all personally identifiable information or non-public information
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
Date: 02/14/2013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortj!a$!e on your home is in default and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pales.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works. To see
if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with
you when you meet with the Counseling ALlency.
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 mu call the
Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired
hearing can call (717) 780 -1869).
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact 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 RVIPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI 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 PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
1
Date: 02/14/2013
HOMEOWNER'S NAME(S): NANCY ELLA WALKER
PROPERTY ADDRESS: 219 Marion Avenue, Carlisle, PA 17013
LOAN ACCT. NO.: _77791
ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR M &T BANK
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.
YOU SHOULD FILE HEMAP APPLICA TION SOONAS POSSIBLE IFYOU
HA VE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK
DATE OF THIS NOTICE AND FILE ANAPPLICA TION WITH PHFA WITHIN30 DAYS OF
THAT MEETING, THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROM
STARTING FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN
THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE
TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM
STARTING FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY
APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN f
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 (Bring it up to date)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 219 Marion Avenue, Carlisle, PA 17013 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 06/01/2012 thru 02/14/2013
(6 mos. at $499.44 /month) $2996.64
(3 mos. at $838.09 /month) $2514.27
(b) Late charges: $52.86
(c) Other charges; Escrow, Inspec., NSF Checks:
Escrow Advance — $1,806.35
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $7,370.12
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 $7,370.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's
check, certified check or money order made payable and sent to:
CHASE
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 ri hts to accelerate the mortuaj!e
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 pay attorney's fees
4
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 paying the total amount then past due plus any late or other charges then due
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements
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: 0114 -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@ipmchase.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
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
Comprehensive Housing
UUN FINARR.�'2 -14, Y; 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 / 888.511.2227
www.Gccsi)a.org
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactdcounty.o
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 / 717.249.0789
www.r-chra.com
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.ora /oathstone va.htm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.ora
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
E..xhibit
*Exhibit has been redacted to remove allpersonally identifiable information or non-public information
k-.
Prepared By 1 Return To: z
E.Lance/NTC, 2100 Alt. 19 North,
Palm Harbor, FL 34683
(800)34 9152
Loan :M791
003900
Tax Code/PIN/0PI #: 29 -17- 1585 -078A
11111111111111111111111111111111111111111111111 1 1 1 1 III I
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 M &T
BANK, ITS SUCCESSORS AND ASSIGNS PO BOX 2026, FLINT, MI, 48501 (MERS Address: 1901 E
Voorhees Street, Suite C, Danville, IL 61834) by these presents does convey, grant, 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 is dated 10/05/2007, in the amount of $78,000.00, made by MAX ELSWORTH WALKER AND
NANCY ELLA WALKER to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE FOR M &T BANK, recorded on 10/15 /2007, in the Office of the Recorder of Deeds of
CUMBERLAND County, Pennsylvania, in Book n/a, Page n/a, and/or Document # 200739559. .
Property is commonly known as: 219 MARION AVE. TWP. OF NORTH MIDDLETON, CARLISLE, PA 17013.
Dated on n!t LAAP—J (NIlIR/DD/YYYY)
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR M &T BANK, ITS
SUCCESSORS AND ASSIGNS
By:
u
ASST. SECRETARY
PAGE
JPCAS 17676018 -1 CHASE CJ4206067 Nl MIN 100050300006442439 MERS PHONE 1- 888 - 679 -6377'
[CJ FRMPA1
{ {IIIII IIIII {IIIII {I {I IIIII IIIII IIII{ 11111 {III {III
*17676018*
Loan &PAR791 r
I Ililll Illll Illll Illll IIIII 1111111111 IIIII IIIII IIIII Ilil IIII
STATE OF LOUISIANA PARISH OF OUACHITA p "
On 01 1 'U6 12 (MM(DD/YYYY), before me appeared �G LI �(' W �, Scf �p •-�
to me personally known, who did say that he/she/they is /are the ASST. SECRETARY of MORTGA$E
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR M &T BANK, ITS SUCCESSORS
AND ASSIGNS and that the instrument was signed on behalf of the corporation (or association), by authority
from its board of directors, and that he/she/they acknowledged the instrument to be the free act and deed of the
corporation (or association).
000
Notary Public - State of LOUISIANA
Commission expires: Upon My Death
Assignment of Mortgage from:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR M &T BANK, ITS
SUCCESSORS AND ASSIGNS PO BOX 2026, FLINT, MI, 48501 (MERS Address: 1901 E Voorhees
Street, Suite C, Danville, IL 61834)
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)
Mortgagor: MAX ELS WORTH WALKER AND NANCY ELLA WALKER
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: 219 MARION AVE. TWP. OF NORTH MEDDLETON
CARLISLE, PA 17013
CUMBERLAND
(Borough or Township, if stated), Commonwealth of Pennsylvania.
Being more particularly described in said mortgage.
c
I, x(,"46 1 ( 501 D u•I` -r . , hereby certify that the below information and address for the
assiggnnee are correct:
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE,
MC 8000, MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE)
By:
ASST. SECRETARY
* 17676018* JPCAS 17676018 -1 CHASE CJ4206067 NI M 100050300006442439 MERS PHONE AGE 2
IN
1- 888 -679 -6377 [C] FRMPAI
11111118111111111111111111181 !IIII 11111 1 11111111
*17676018*
i
I
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
C7 r.a t'7
C E— "1
JPMORGAN CHASE BANK, NATIONAL Mir
=M fw
ASSOCIATION -,,
Plaintiffs c�
Case No.
vs. y —
c-3 - ; --
c-) -;
NANCY ELLA WALKER _
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 submitted:
- Al A�
y
(Signature of Couns r Plaintiff)
Date
Cumberland County Residential ]Mortgage Foreclosure Diversion Program
Date Financial Worksheet
Cumberland County Court of Common Pleas Docket #
BORROWER REQMT FOR i ASSISTANCE
To complete•your request for hardship assistance, your lender must consider your
circumstances to det+erinine.. possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMER/P111M.,�lti, APPLICANT
Borrower name(s):
Property Address:
City: _State: --.-__ _ Zip:
Is the property for s Yes EJ N o ❑ Listing slate: - Price: S
Realtor Warne: Realtor Phone:
Borrower Occupied? Yes Lj No Lj
Mailing Address (if different):
City; state: Zip:
Phone Numbers: Home: pace:
Cell: bather:
1✓xnail:
of people in household: How long?
.Mailing Address;
City: State: zip:
Phone Numbers: Dome: Office:
Email: Cell: Other:
# ofpeople in household: -- How long?
First Mortgage Lender:
Type of Loan:
Loan Number:
Date You Closed Your Loam:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ _ Included Taxes & lnsurance:
Date of Last Payment:
Primary Reason for Default•
is the loan in Bankruptcy? Yes E] No []
I f yes provide cranes, location of court, case number & attorney:
Assets Amount Owed V alue:
Home: $ $
Other Real Estate: $ - -- - $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #l: Model: Year:.
Amount owed: 'value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles boats, Model:
Year. Amount owed: Value
Montli[y Income
Name of Employers:
1.
2.
3.
Additional Income Description (trot wages). -
I • ". - . monthly amount:
2. -- - monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Exp nses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT - - 13XI'ENSE AMOUNT
Moqgaae Food
MqdS Utilities
Car Pa ens Condo/Nei . Fees
Auto Insurance Mod. not covered
Auto fuel /re irs Other prop, payment
Install. Loan Pa mcnt Cable TV
Child Sqp
port/Alim, S riding Mone
1]a 1C4ild Care/T'uit, Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency's
Yes El No 0
If yes, please provide the following information:
Counseling Agency:
Coutisel.or:
Phone (Office): Fax:
+ r
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes• [3 No Q
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ❑ No Q
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 (:carne):
Contact: Phone:
TAVe, authorize the above
named to use /refer this information to my lender /servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. IfWc
understand that I/we arn/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature — Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
'llf Past 2 bank statements
Proof of any expected income for the last 45 days
_Y` Copy of a current utility bill
, Y Letter explaining reason for delmi quency and any supporting documentation .
(hardship letter)
Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson k
Sheriff = •L E _ k^F)Cr L
Jody S Smith
Chief Deputy MAY 15 PM I: 1
.
Richard W Stewart
Solicitor OF ,E THE REF-dFr CUMBERLAND COUtz f Y
PENNSYLVANIA
JPMorgan Chase Bank, National Association
vs. Case Number
Nancy Ella Walker 2013-2639
SHERIFF'S RETURN OF SERVICE
05/13/2013 06:21 PM- Deputy Dennis Fry, 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: Nancy
Ella Walker at 219 Marion Avenue, North Middleton, Carlisle, PA 17013.
DEN KS FRY, DES T
SHERIFF COST: $34.78 SO ANSWERS,
May 14, 2013 RbNW R ANDERSON, SHERIFF
(c)CountySuite Shoriff,Toleosoft,Inc.
C
JP Morgan Chase Bank,National : IN THE COURT OF COMM,5 PL-RAS "-
G�
Association : CUMBERLAND COUNTYrnr+J
c/o 3415 Vision Drive : PENNSYLVANIA a-
Columbus, OH 43219
Plaintiff " '
V. : Docket No. 13-2639 -'
Nancy Ella Walker
219 Marion Avenue
Carlisle, PA 17013 : CIVIL ACTION-
Defendant : MORTGAGE FORECLOSURE
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012, governing the
Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned
hereby certifies as follows:
1. Defendant is owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
co
Sign ure of Defendant's Counsel/Appo' ted Date
Legal Representative
Signature f Defendant Dat
JP Morgan Chase Bank, National : IN THE COURT OF COMMON PLEAS
Association : CUMBERLAND COUNTY,
c/o 3415 Vision Drive : PENNSYLVANIA
Columbus, OH 43219
Plaintiff Mco
=M @'
V. : Docket No. 13-2639
>C7 :
Nancy Ella Walker _
219 Marion Avenue '
Carlisle, PA 17013 : CIVIL ACTION-
Defendant : MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I,Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant,
Nancy Ella Walker, hereby certify that I am serving a copy of the Praecipe for Entry of
Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney, on
the following date and in the manner indicated below:
U.S. First Class Mail" Postage Pre-Paid
Salvatore Filippello,Esq.
KML Law Group
Suite 5000-BNY Mellon Independence Center
701 Market Street
Philadelphia,PA 19106
MIDPENN LEGAL SERVICES
DATE: 0(p (zo(z o-.Lq�� z K,-A, �
Jaime M. Haley, Esquire
Attorney for Defendants
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
JP Morgan Chase Bank, National : IN THE COURT OF COMMON PLEAS
Association : CUMBERLAND COUNTY,
c/o 3415 Vision Drive ; PENNSYLVANIA
Columbus, OH 43219
Plaintiff V.
Docket No. 13-2639
Nancy Ella Walker •
219 Marion Avenue
Carlisle,PA 17013 : CIVIL ACTION-
Defendant : MORTGAGE FORECLOSURE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of MidPenn Legal Services on behalf of the Defendant,
Nancy Ella Walker, in the above matter,representing the Defendant in the Cumberland County
Residential Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE: 6 o q zncs tILQ
Jaime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID#205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
JP Morgan Chase Bank,National IN THE COURT OF COMMON PLEAS
Association CUMBERLAND COUNTY,
c/o 3415 Vision Drive PENNSYLVANIA
Columbus, OH 43219 C71,
C-
Plaintiff X a;
V. Docket No. 13-2639
-<>
Nancy Ella Walker „ :Z.C-)
219 Marion Avenue 5:c::: Cz
Carlisle, PA 17013 CIVIL ACTION-
Defendant MORTGAGE FORECLOSURE
CASE MANAGEMENT ORDER
AND NOW, this of day of 2013, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on AQ/3at 4, in
at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet” (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of the
plaintiff/lender is not available by telephone during the Conciliation Conference, the
court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
DISTRIBUTION:
Zme M.Haley, Esquire
MidPenn Legal Services
401 E. Louther Street, Ste 103
Carlisle,PA 17013
For the Defendant
alvatore Filippello,Esq.
KML Law Group
Suite 5000-BNY Mellon Independence Center
701 Market Street.
Philadelphia,PA 19106
For the Plaintiff
P
JP MORGAN CHASE BANK, IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION—LAW
VS. NO. 13-2639 CIVIL
NANCY ELLA WALKER,
Defendant MORTGAGE FORECLOSURE
ORDER
AND NOW,this 9 day of August, 2013, at the request of the parties,the
conciliation conference in the above matter set for August 9, 2013, is continued to Friday,
September 27, 2013, at 4:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin ess, P. J.
--'Nathan Wolf, Esquire
For the Plaintiff
,-`�Jaime Haley, Esquire
For the Defendant -
:rlm
of es LL
JP MORGAN CHASE BANK, IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION—LAW
vs. NO. 13-2639 CIVIL
NANCY ELLA WALKER,
Defendant MORTGAGE FORECLOSURE
ORDER
AND NOW, this Zs" day of September, 2013, at the request of the parties, the
conciliation conference in the above matter set for September 26, 2013, is continued to
Thursday,November 14, 2013, at 3:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevi A. Hess, P. J.
./Nathan Wolf, Esquire
For the Plaintiff
�me Haley, Esquire
For the Defendant
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JP MORGAN CHASE BANK, IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, CUMBERLAND COUNTY, PENNSYLVAN4
Plaintiff rl w C:1 rn
-;
CIVIL ACTION-LAW zr� ~=
vs. NO. 13-2639 CIVIL �� '
r-z CA C
NANCY ELLA WALKER,
Defendant MORTGAGE FORECLOSURE 3:cz d =
IN RE: CONCILIATION CONFERENCE
Present at a conciliation conference held November 14, 2013, were Nathan Wolf,
Esquire, local counsel for the plaintiff; Jaime Haley, Esquire, attorney for the defendant; the
homeowner,Nancy Ella Walker; and her daughter, Wendy Anderson.
Numerous prior attempts to submit complete documents in this case have been
unsuccessful and the plaintiff has signaled its intention not to review this matter further.
Nonetheless and in order to give the homeowner and her family the opportunity to address this
matter one final time, the defendant will be given thirty (30) days within which to submit
required documents and seek further review of this matter. Unless a request for a continued
conciliation conference is lodged with the Court and is unopposed prior to the close of business
on Tuesday, December 17, 2013, the Court will entertain the plaintiff's petition for removal of
this matter from the Cumberland County Mortgage Foreclosure Diversion Program.
November 14, 2013 - X
Kevin . Hess, P. J.
Nathan Wolf, Esquire
For the Plaintiff
ZJ'aime Haley, Esquire
For the Defendant
C es / lkI LL
t=nl
JP Morgan Chase Bank, National : IN THE COURT OF COMMON PLEAS
Association : CUMBERLAND COUNTY,
c/o 3415 Vision Drive : PENNSYLVANIA
Columbus, OH 43219
•
Plaintiff
•
i
v. : Docket No. 13-2639 r
PI
Nancy Ella Walker
c,
219 Marion Avenue •
Carlisle, PA 17013 : CIVIL ACTION-
Defendant : MORTGAGE FORECLOSURE ..;
MOTION TO REQUEST A CONCILIATION CONFERENCE
NOW COMES, Defendant,Nancy Ella Walker,by and through her attorney, Jaime M. Haley,
Esq.,MidPenn Legal Services, and respectfully files the following Motion to Request a Conciliation
Conference and respectfully represents:
1. A Mortgage Foreclosure Diversion Program conciliation conference was held in the
above-listed matter on November 14, 2013.
2. The bank requested additional documents at that time.
3. Defendant submitted the documents requested for the bank's review on December 16,
2013.
WHEREFORE,Defendant respectfully requests that this Honorable Court schedule a conciliation
conference for a date and time as soon as is convenient to the Court's schedule.
Respectfully submitted,
Date: 12/( (-cc(3 cy,`(oz__(/Le_,,,/„
Jame M.Haley, Esq.
Attorney For Defendant
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717)243-9400 ext. 2513
Pio
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of perjury of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated: v l 3 l�( (1714 tti1W-le-<--
N/ancy Ella/Walker, Defendant
JP Morgan Chase Bank, National : IN THE COURT OF COMMON PLEAS
Association : CUMBERLAND COUNTY,
do 3415 Vision Drive : PENNSYLVANIA
Columbus, OH 43219
Plaintiff •
v. : Docket No. 13-2639
Nancy Ella Walker •
219 Marion Avenue •
Carlisle, PA 17013 : CIVIL ACTION-
Defendant : MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant,
Nancy Ella Walker, hereby certify that I am serving a copy of the Motion to Request Conciliation
Conference on the Plaintiff, through their attorney, on the following date and in the manner
indicated below:
U.S. First Class Mail, Postage Pre-Paid
Nathan C. Wolf, Esq.
Wolf&Wolf
10 West High Street
Carlisle, PA 17013
MIDPENN LEGAL SERVICES
t 'ttp DATE: j 2 I I (ZQ(3 t C t, (� Ck- f
aime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717) 243-9400
JP Morgan Chase Bank, National : IN THE COURT OF COMMON PLEAS
Association : CUMBERLAND COUNTY,
c/o 3415 Vision Drive : PENNSYLVANIA
r--,
Columbus, OH 43219 . i°-: -;.
c
Plaintiff • -3: ��'
• Cr; �_'�-
v. : Docket No 13-2639
mss-- _,,,, 7:3 C:
-tom' kO `_ C )
Nancy Ella Walker :4 , -
219 Marion Avenue • j-
;;, f .
Carlisle, PA 17013 : CIVIL ACTION- '"") :''•
Defendant : MORTGAGE FORECLOSURE
ORDER
AND NOW, this /9 day of ''r , 2013, upon consideration of Defendant's
Motion to Request Conciliation Conference, it is hereby ORDERED and DECREED that:
The parties and their counsel are directed to participate in a court-supervised conciliation
�-E�2u /91; tf
Conference on 4� at y�Qd�in in at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
4)
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J.
JP MORGAN CHASE BANK, IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION—LAW
VS. NO. 13-2639 CIVIL
NANCY ELLA WALKER,
Defendant MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 2'✓' day of January, 2014, at the request of counsel, the conciliation
conference set for February 14, 2014, is continued to Friday, February 21, 2014, at 4:00 p.m. in
Chambers of the undersigned.
BY THE COURT
'-�', , /y,
Kevi A. Hess, P. J.
Nathan Wolf, Esquire
For the Plaintiff
Jaime Haley, Esquire
For the Defendant
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CD
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JP MORGAN CHASE BANK, : IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION—LAW
vs. : NO. 13-2639 CIVIL
NANCY ELLA WALKER, •
Defendant : MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 2 z day of January, 2014, the conciliation conference set for
February 21, 2014, is continued to Wednesday, February 26, 2014, at 4:00 p.m. in Chambers of
the undersigned.
BY THE COURT
/4 AZ
Kevi • . Hess, P. J.
i Nathan Wolf, Esquire
For the Plaintiff
✓ Jaime Haley, Esquire
For the Defendant
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JP MORGAN CHASE BANK,
NATIONAL ASSOCIATION,
Plaintiff
vs.
NANCY ELLA WALKER,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
• CIVIL ACTION — LAW
: NO. 13-2639 CIVIL
Defendant : MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 3/ day of March, 2014, upon request of counsel for the plaintiff,
this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program
and the stay entered in this case is lifted.
Xlathan Wolf, Esquire
For the Plaintiff
V-Jaime Haley, Esquire
For the Defendant
:rlm
CC131.C.S r2.4.-t [Er—Li
BY THE COURT
Kevin Hess, P. J.
:rtur•
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
Columbus, OH 43219
VS.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 13-2639
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 4/1/2013
to Date of Sale per
diem at $13.37
(Costs to be added)
By:
$82,080.09
KML L ROUP, P.C.
Michael c eever Pa. ID 56129
Jay E. Kivitz • a. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
*P S Attorneys for Plaintiff
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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
Columbus, OH 43219
vs.
NANCY ELLA WALKER
(Mortgagor(s) and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
2,7ilt''AP? 21 PH 1:15
+i i3CRL.1414) COUNTY
vENNS YLti'f NIA
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 13 -2639
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:
219 Marion Avenue
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
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
219 Marion Avenue
Carlisle, PA 17013
COMMONWEALTH OF PENNSYLVANIA, DEPT.
OF REVENUE INHERITANCE, TAX DIVISION
1131 Strawberry Sq., 6th Floor
Harrisburg, PA 17128
DEPARTMENT OF PUBLIC WELFARE
ESTATE RECOVERY PROGRAM
P.O. Box 8486, Willow Oak Building
Harrisburg, PA 17105 -8486
INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH
1001 Liberty Avenue
Thirteenth Floor, Suite 1300
Pittsburgh, PA 15222
MIDPENN LEGAL SERVICES
c/o Jaime M. Haley, Esq.
401 Louther Street, Ste 103
Carlisle, PA 17013
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:
40/2011
By:
KML LAWG)�tOUP, P.C.
Michael M eeve Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
JJ?(iffl4 mcC
KiVIL 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
do 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s
13 -2639
«114e
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P E rip
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 13 -2639
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: WALKER, NANCY ELLA
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
Your house at 219 Marion Avenue, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $82,080.09 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 -2639
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717 - 240 -6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717 - 240 -6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
13 -2639
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717 - 243 -9400.
2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1- 866 - 413 -2311 or via email at
homeretention @kmllawgroup.com.com. Call Seth at 215- 825 -6329 or fax 215 -825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of
116891FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215- 627 -1322
Attorney for Plaintiff
2'.'JR APR 21 Pri 1: €5
L.0 L 1. I D Cull'
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 13 -2639
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By: .J h
KML LAW e i I • , P.C.
Michael McK: er ".. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
,- 13-016{ry Recftc31bi6 -0
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
Vs.
NANCY ELLA WALKER
WRIT OF EXECUTION
NO 13 -2639 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $82,080.09 L.L.: $.50
Interest FROM 4/1/2013 TO DATE OF SALE PER DIEM AT $13.37
Atty's Comm: Due Prothy: $2.25
Atty Paid: $183.53 Other Costs:
Plaintiff Paid:
Date: 4/21/14
(Seal)
David D. Buell, Prothonota
Deputy
REQUESTING PARTY:
Name: JENNIFER FRECHIE, ESQUIRE
Address: KML 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. 316160
In the Court of Common Pleas of Cumberland County
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
(Mortgagor(s) and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
PRAECIPE FOR JUDGMENT
4 Z r 3
-
No. 13 -2639
co
r" t c
—0 CD
c) r
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 NANCY ELLA WALKER by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 4/1/2013 to
Date of Sale per diem at $13.37
Total
(Assessment of Damages attached)
$82,080.09
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 party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
By:
KML LAW GROUP l C.
Michael McKeever Pa 56129
_Jay E. Kivitz Pa. ID 267 9
Lisa Lee Pa. ID 78020
_Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
r Andrew F; rQaa OIIL� 92382
Y t orneys or P anti !h' 31 bl b0
AND NOW i r Lt 1 I LI , Judgment is entered in favor of
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION and against NANCY EL 11 W • R b a ault for want o
an Answer and damages assessed in the sum of $82,080.09 as per the above certification
Prothonotary
GbtAsib.sp-A4i4m
0
C 7(oUo a�
No12 nom,
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
NANCY ELLA WALKER
(Mortgagors and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
vs.
Defendant(s)
No. 13 -2639
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above - captioned matter has been entered against you.
David D. Buell
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
Prothonotary
By:
tY�
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
116891FC
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.
TO:
NANCY ELLA WALKER
WALKER, NANCY ELLA
219 Marion Avenue
Carlisle, PA 17013
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
3415 Vision Drive
Columbus, OH 43219 Plaintiff
vs.
NANCY ELLA WALKER
(Mortgagor(s) and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Defendant(s)
TO: NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
DATE OF THIS NOTICE: April 4, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 13 -2639
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 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 ONFFR 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
By:
KML ` ROUP, P.C.
M a - McKeever Pa. ID 56129
Lisa L • Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
yk L. Oflazian Pa. ID 312912
alvatore Filippello Pa. ID 313897
Jennifer Lynn Frechie Pa ID 316160
215- 627 -1322
Attorneys for Plaintiff
116891FC
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.
TO:
Jaime M Haley, Esq.
Midpenn Legal Services
401 Louther Street, Ste 103
Carlisle, PA 17013
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
3415 Vision Drive
Columbus, OH 43219 Plaintiff
vs.
NANCY ELLA WALKER
(Mortgagor(s) and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Defendant(s)
TO: Jaime M Haley, Esq.
401 Louther Street, Ste 103
Carlisle, PA 17013
DATE OF THIS NOTICE: April 4, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 13 -2639
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. THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOTJ 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
By: 1,. ( ►�
KML LA UP, P.C.
Michael cKeever Pa. ID 56129
Lisa Lee ' a. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
JSalvatore Filippello Pa. ID 313897
Jennifer Lynn Frechie Pa ID 316160
215 -627 -1322
Attomeys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
Plaintiff
vs.
NANCY ELLA WALKER
Defendant(s)
NO. 13 -2639
VERIFICATION OF NON - MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ( "DMDC ") website
operated by the United States Department of Defense ( https:// www. dmdc .osd.mil/appj /scra/scraHome.do)
for the following individual(s): NANCY ELLA WALKER, has a last known residence of 219 Marion
Avenue, Carlisle, PA 17013. 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.
By:
KML LAW GROUP, P.
Michael McKeever Fta�l ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew 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
�/ Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
Department of Defense Manpower Data Center
Results as of : Apr-16-2014 01:42:18 PM
SCRA 10
Status Rtpoit
Pursuant to Servicemembers Civil Relief Act.
Last Name: WALKER
First Name: NANCY
Middle Name: ELLA
Active Duty Status As Of: Apr -16 -2014
On Active Duly On Active Duty Status Date
Active Duty Start Date
Active Duly End Date
Status
Service Component
NA
NA - .,'
- ` No ' '\
NA
This response reflects the Individuals' active duly 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 Cali -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
` NA `
No
NA
This response reflects whether the individual or his/her unit has received earhinotificntion 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.
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 /PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
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: A8LE6F6FYODORFO
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
do 3415 Vision Drive
Columbus, OH 43219
VS.
NANCY ELLA WALKER
(Mortgagor(s) and Record owner(s))
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 13-2639
ORDER FOR JUDGMENT
Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, and against
NANCY ELLA WALKER for failure to file an Answer in the above action within (20) days from the date of service of the
Complaint, in the sum of $82,080.09.
By:
KML LAW UP, 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. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys. for Plaintiff
JiT. Evtd titir Frethie 1(of (90
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 NANCY E LA WALKER, 219 Marion Avenue Carlisle, PA
17013;
By:
KML ROUP, 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. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
jjt,VI II FreCh 31 6[00
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $73,635.06
Interest from 05/01/2012 through $4,471.83
03/31/2013
Reasonable Attorney's Fee $1,650.00
Accrued Late Charges $52.86
Escrow Advance $2,144.34
Property Inspections $126.00
AND NOW, this
13- 2639/116891FC
By:
$82,080.09
KML LAW 4RQUP, P.C.
Michael Mc eever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
ilJZvtv� i v 1 c tr I b1 b°
day of �y t I , 2014 damages are assessed as above.
KML LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and
Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
F' PRO -OFFICE
(IF
THE PROTf4QNQ T,
2014 AUG 14 PM 2;
CUMBER,/
C
titv. S
116891FC
CF: 05/10/2013
SD: 09/03/2014
$82,080.09
THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Term
No. 13-2639
Andrew Hauck, 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:
Personal Service by the Sheriffs Office/competent adult (copy of return attached).
Certified mail by KML Law Group, P.C. (copy of 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. (copy of 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,
BY: Andrew Hauck
Legal Assistant
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; et
seq.
Plaintiff (Petitioner)
V.
NANCY ELLA WALKER; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 13-2639
Sheriffs Sale Date: 9/3/2014
AFFIDAVIT OF SERVICE
El Complaint El Summons El Other: NOTICE OF SALE
I, KEVEN CHASE, certify that 1 am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
served NANCY ELLA WALKER the above process on the 7 day of May, 2014, at 1:08 o'clock, PM, at 219 Marion Avenue Carlisle, PA 17013 , County of
Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
Q By handing a copy to the Defendant(s)
Description: Approximate Age 56-60 Height 5'10 Weight 170 Race WHITE Sex FEMALE Hair BLONDE
Military Status: RI No ❑ Yes Branch:
Commonwealth/State of Rai
County of 13‘,0/
) SS:
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, deposes the following:
Ke✓ a.. e L A I r to me known, who being
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct.
(Signature of Affiant)
Subscribed and sworn to fnr' n,,
this 4 dayett 4.0?'y .
File Number:116891 FC
Case ID #:3968605 Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. Afflerbach, Notary Public
Washington Township, 9erks County
My Comrnisslon Expires November 18, 2017
Name and Address of Sender
3OLDBECK
SUITE 5000
01 MARKET
01 MA EESTREET PA
I -I❑
19106-1532
Check type of mail or service:
❑ Certified- ❑Recorded Delivery (International)
0 COD ❑ Registered
❑ Delivery Confirmation ❑ Return Receipt for Merchandise
Express Mail ❑ Signature Confirmation
❑ Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage
Fee
Handling
Charne
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
RR
Fee
1
DOMESTIC RELATIONS OF CUMBERLAND
COUNTY
PO Box 320
Carlisle, PA 17013
TENAN
219 Mar
Carlisle,
'S/OCCUPANTS
on Avenue
PA 17013
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Health and Welfare
P.O. Box 2675
OF PUBLIC WELFARE -
Support Enforcement
Bldg. - Room 432
17105-2675•Isr.t
UUM
DEPT.
-DIVISIO
1131 St
Harrisburg.
DEPARTMENT
ESTATE
P.O. Box
I larrisburg,
INTERNAL
PROCEDURES
1001 Liberty
Thirteen:h
Pittsburgh,
MIDPENN
Nn .laima
NWEALTH
F REVENUE
awberry Sq.,
PA 17128
OF
RECOVERY
8486, Wil
PA 17105-840G
REVENUE
BFANCH
Avenue
Floor, Suite
PA 15222
LEGAL
M Haley
her Street,
PA 17013
OF PENNSYLVANIA,
INHEFITANCE,
6th Floor
PUBLIC
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ow Oak Building
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1300
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Total Number of Pieces To I Number of Pieces /
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of receiving employee)
See Privacy Act Statement on Reverse
PS Form 3$77' Fet uary 2002 (Page 1 of 2)
Complete by Typewriter, Ink, or Ball Point Pen
116$91 FC Cumberland County Sale Date: 09/03/2014
NANCY ELLA WALKER
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
ASSOCIATION
do 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Defendant(s)
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 13-2639
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:
219 Marion Avenue
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
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
219 Marion Avenue
Carlisle, PA 17013
COMMONWEALTH OF PENNSYLVANIA, DEPT. OF REVENUE INHERITANCE,
TAX DIVISION
1131 Strawberry Sq., 6th Floor
Harrisburg, PA 17128
DEPARTMENT OF PUBLIC WELFARE
ESTATE RECOVERY PROGRAM
P.O. Box 8486, Willow Oak Building
Harrisburg, PA 17105-8486
INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH
1001 Liberty Avenue
Thirteenth Floor, Suite 1300
Pittsburgh, PA 15222
Midpenn Legal Services
c/o Jaime M. Haley, Esq.
401 Louther Street, Ste 103
Carlisle, PA 17013
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: August 12, 2014
KML Law Group, P.C.
BY: Andrew Hauck
Legal Assistant
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
_FILED -OFFICE
PROTHONOTARY
HE
rg�
2Th SEP 15 PH 2: !
CUMBERLAND COUNTY
PENNSYLVANIA
PEZE OF THE SHERIFF
JPMorgan Chase Bank, NA
vs.
Nancy Ella Walker
Case Number
2013-2639
SHERIFF'S RETURN OF SERVICE
06/16/2014 05:46 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 219 Marion Avenue, Carlisle, PA 17013, Cumberland
County.
09/02/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014
09/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $681.40
September 12, 2014
tc} CountvSu:ie Sherif Teteosoft. Inc,
SO ANSWERS,
RONR ANDERSON, SHERIFF
r
On April 24, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
North Middleton Township, Cumberland County, PA,
mown and numbered as, 219 Marion Road,
Carlisle, as Exhibit "A" filed with
this Writ and by this Reference incorporated herein.
Date: April 24, 2014
By:
Real Estate Coordinator
" The Patriot -News 'Co.
1900 Patriot Drive
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
tie liatriot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Amy Kotula, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of
Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither 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.
2013-2639 Civil Term
JPMORGAN CHASE BANK,
NA
vs.
NANCY ELLA WALKER
Atty: Michael McKeever
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 219 Marion
Avenue
Carlisle, PA 17013
SOLD as the property of NANCY
ELLA WALKER
TAX PARCEL #17-1
585-078A-0000000-29
This ad ran on the date(s) shown below:
07/13/14
07/20/14
07/27/14
itkec(
Sworn to 13d ubscribed before me this 20 day of August, 2014 A.D.
Nottry P blic
COMMONWEALTH OP PENNSYLVANIA
NOTARIAL SEAL
Sheryl Marie Leggore, Notary Public
Hampden Twp., Cumberland County
My Commission Expires July 16, 2018
MEM9ER. PENNSYLVANIA ASSOCIATION OF NOTARIES
•
the PattiOtsNeWS
Now you know
2020 Technology Parkway
Mechanicsburg, PA
(717) 255-8237
BILL TO: Cumberland County Sheriffs Office
Cumberland County Court House
Carlisle, PA 17013
ACCT. #
2260
DUPLICATE BILL
Date Description Sale # Size Rate Net Cost
Of Ad
07/13/14
Sheriff Sale
2639
4.11
$14.29
$ 58.73
07/20/14
Sheriff Sale
2639
4.11
$14.29
$ 58.73
07/27/17
Sheriff Sale
2639
4.11
$14.29
$ 58.73
Notary Fee
$5.00
Digital Penn Live Charge
6.83
TOTAL DUE FOR THIS SALE:
JLC
$ 188.02
LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14
Writ No. 2013-2639 Civil
JPMORGAN CHASE BANK, NA
vs.
NANCY ELLA WALKER
Atty.: Michael McKeever
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 219 Marion
Avenue, Carlisle, PA 17013.
SOLD as the property of NANCY
ELLA WALKER.
TAX PARCEL #17-1 585-078A-
0000000-29.
105
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 11, July 18 and July 25, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
sa Marie Coyne, Lditor
SWORN TO AND SUBSCRIBED before me this
25 day of July, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018
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 19106-1532
215-627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK; NATIONAL
ASSOCIATION
do 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 13-2639
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
ptia
G -� CvF
S ll l�
go "
De s
Interest from 4/1/2013
to Date of Sale per
diem at $13.37
(Costs to be added)
$82,080.09
AW GROUP, P.C.
el McKeever Pa. ID 56129
. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
' , Attorneys for Plaintiff
Sa. as
...�L VictUAck. w. ale()C6 (1)
31-7-7q
r
C,)
CD
N)
et# )84(u33 A- 08 Qti tsec
�i�315o3S Uj.
ALL that certain tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described as
follows:
BEGINNING at a point on the Northerly line of Marion Road at a stake which in 288 feet
East from the Northeast intersection of Maplewood Road and Marion Road; thence by
the Easterly line of lands now or formerly of Meek, North 18 degrees 30 minutes East
140 feet to a point at a stake; thence by lands now or formerly of Bucher, South 71
degrees 30 minutes East 85 feet to a point at a stake; thence by lands now or formerly of
Bucher, South 18 degrees 30 minutes West 140 feet to a point on the said Northerly line
of Marion Road; thence by the said line of Marion Road, North 71 degrees 3Q minutes
West 85 feet to a point at a stake, the place of BEGINNING.
BEING improved with a one story frame dwelling known as No. 219 Marion Road.
IMPROVEMENTS a one story frame dwelling known as No. 219 Marion Road.
MUNICIPALITY North Middleton Township
BEING PREMISES: 219 Marion Avenue, Carlisle, PA, 17013
SOLD as the property of Nancy Ella Walker
TAX PARCEL # 17-1585-078A-0000000-29
BEING the same premises which Max E. 'Walker by deed dated 4/26/1977 and recorded
4/22/1977 in Cumberland County in Deed Book Volume 27 at Page 934 granted and
conveyed unto Max E. Walker and Nancy Ella Walker, his wife and the said Max E. Walker
departed this life on 2/18/2008, vesting title solely in Nancy Ella Walker.
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
5
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
do 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
(Mortgagor(s) and Record Owner(s))
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 13-2639
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:
219 Marion Avenue
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
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
219 Marion Avenue
Carlisle, PA 17013
COMMONWEALTH OF PENNSYLVANIA, DEPT. OF
REVENUE INHERITANCE, TAX DIVISION
1131 Strawberry Sq., 6th Floor
Harrisburg, PA 17128
DEPARTMENT OF PUBLIC WELFARE
ESTATE RECOVERY PROGRAM
P.O. Box 8486, Willow Oak Building
Harrisburg, PA 17105-8486
INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH
1001 Liberty Avenue
Thirteenth Floor, Suite 1300
Pittsburgh, PA 15222
Midpenn Legal Services
c/o Jaime M. Haley, Esq.
401 Louther Street, Ste 103
Carlisle, PA 17013
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 penaltie CS. Section 4904 relating to unsworn
falsification to authorities.
DATED: 12.-/ 7-4 I
Bv:
KM W GROUP, P.C.
M'. cKeever Pa. ID 56129
Ja ' - . vitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
//Attorneys for Plaintiff
4(N/f'c-toril Q.. W . C 41 ' Pa. CP 31770
KML Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
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13-2639
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
NANCY ELLA WALKER
Mortgagor(s) and Record Owner(s)
219 Marion Avenue
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 13-2639
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: WALKER, NANCY ELLA
NANCY ELLA WALKER
219 Marion Avenue
Carlisle, PA 17013
Your house at 219 Marion Avenue, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 03, 2015,.at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $82,080.09 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 fling 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.
13-2639
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
&Irvine Row
Carlisle, PA 17013
717-243-9400
•
13-2639
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
116891 FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.cepa.net
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
Vs. NO 13-2639 Civil Term
CIVIL ACTION — LAW
NANCY ELLA WALKER
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $82,080.09 L.L.:
Interest FROM 4/1/2013 TO DATE OF SALE PER DIEM AT $13.37
Atty's Comm: Due Prothy: $2.25
Atty Paid: $893.43 Other Costs:
Plaintiff Paid:
Date: 12/30/14 Ifid;LALI, /RiL
David D. Buell, Prothonotary
(Seal) '�Oit v 4il/_
Dep>i
REQUESTING PARTY: .
Name: VICTORIA W. CHEN, ESQUIRE
Address: KML LAW GROUP, P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 317741