Loading...
HomeMy WebLinkAbout13-3236 Supreme Court of Pennsylvania coup of Comlin Pleas r I X'% 1, For Prothonotaq 1!5e 0111r: }, ail' cbvetn Weet t �# Cum �erlan Co t� The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other pape rs as required bylaw or rules of court. - -- Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: JPMORGAN CHASE BANK, NA MATTHEW WEBB G SUSAN K. WEBB T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented Pro Se Litigant ~ Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL i ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other ❑ Employment dispute: E mass tort) ❑ Slander/Libel Defamation Discrimination C ❑ Employment Dispute: Other ❑ Other T ❑ Other: O MASS TORT ❑ Other N Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY PERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑Ejectme ❑Common Law /Statutory ❑ Toxic Waste 11 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 ❑ Dental ❑ Partition ❑ Quo Warranto 1 ❑Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑Other 11 Other Professional: ❑Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENT R - 701 MARKET STREET S � T PHILADELPHIA, PA 19106 i T H E P R O T H O N O f A 1, f (866) 413 -2311 I A " 20 N' .» � AM i 1 5 JPMORGAN CHASE BANK, NA IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive CUMBERLAND UNITY Columbus, OH 43219 P OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION - LAW MATTHEW WEBB SUSAN K. WEBB AQ4�'►I'�O FORECLOSURE Mortgagor(s) and Record Owner(s) 505 Woodcrest Drive FOR '=SURE Mechanicsburg, PA 17050 No. J 2 , 3D3& Defendant(s) / J NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial 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 provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. O 1 bl, `bpd a LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO 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.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http : / /www.philadelphiafed.orj4 /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 homeretentionka kmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215 -825 -6418. Please reference our Attorney File Number of 121350FC. 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, NA, c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are MATTHEW WEBB, 505 Woodcrest Drive, Mechanicsburg, PA 17050 and SUSAN K. WEBB, 505 Woodcrest Drive, Mechanicsburg, PA 17050, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On June 18, 2010 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to JPMORGAN CHASE BANK, NA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on June 25, 2010 as Instrument #201016846. 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 September 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 30, 2013: Principal Balance ....................................................... ............................... ..$271,927.53 Interest from 08/01/2012 through 03/31/2013 ....................... ......................$8,837.68 Accrued Late Charges ................................. ............................... ........................$669.15 Property Preservation .................................. ............................... ........................$160.00 Property Inspections ..................................... ............................... .........................$98.00 EscrowAdvance ........................................ ............................... ......................$5,270.35 Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $288,612.71 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 has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit `B ". The property securing the mortgage is not the principal residence of the defendant(s) and, therefore, the provisions of Act 91 of 1983 are inapplicable to this action. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $288,612.71, 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 G. UP, P.C. Michael cKeever 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 _N_ Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION Vice President n hereby states that he she is of JPMORGAN CHASE BANK, NA Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: 3 ame: s han`,e 1310V'� Title: Vice President J l #121350FC MATTHEW WEBB and SUSAN K. WEBB E�hifiitA Order No.: 8871650 Loan No.: 1547207795 Exhibit A The following described property: All that certain piece or parcel of land situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, commonly known as 505 Woodcrest Drive, bounded and described as follows: Beginning at a point on the Western line of Deerfield Avenue at the Northern line of Lot No. 17 on the hereinafter mentioned Plan of lots; thence along the Northern line of Lot No. 17 North 60 degrees 46 minutes 49 seconds West sixty -four and eighty -two one- hundredths (64.82) feet to a point; thence along the Eastern line of Lot No. 15, North 06 degrees 41 minutes East one hundred forty-eight and fifty one - hundredths (148.50) feet to a point; thence along the Southern line of Woodcrest Drive, South 83 degrees 19 minutes East eighty -six and thirty-four one - hundredths (86.34) feet to a point; thence still along Woodcrest Drive by a curve to the right having a radius of 173.18 feet, an arc distance of fifty -six and fifty -two one - hundredths (56.52) feet to a point; thence along Woodcrest Drive and along Deerfield Avenue by a curve to the right having a radius of 20 feet, an arc distance of thirty -eight and seven one - hundredths (38.07) feet to a point; thence continuing along Deerfield Avenue, South 44 degrees 30 minutes West ninety -two and sixty -two one - hundredths (92.62) feet to a point; thence still along Deerfield Avenue by a curve to the left having a radius of 260 feet, an arc distance of sixty -nine and thirty-four one - hundredths (69.34) feet to a point, the place of beginning. Subject, nevertheless, to any and all liens, mortgages, easements, covenants, conditions, restrictions, reservations, rights -of -way, zoning ordinances and any and all other matters that are of record or visible on the premises. Being Lot No. 16, Section G, Plan 10, of Good Hope Farms, which Plan was prepared by D.P. Raffensberger Associates and was recorded on May 7, 1973, in Plan Book 23, page 158, in the Office of the Recorder of Deeds In and for Cumberland County, Pennsylvania. Assessor's Parcel No: 10 -17 -1033 -164 Ey, h (B *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5-7734) CHASE P.O. Box 44090 Jacksonville, FL 32231 -4090 March 11, 2013 IIIIIIi, I11111 ,1„IIIilllll„III 00008497 HDLG ZB 7013 -BR160 SUSAN K WEBB 505 WOODCREST DR MECHANICSBURG, PA 17050 Acceleration Warning (Notice of Intent to Foreclose) Account: 1547207795 (the "Loan ") Property Address: 505 WOODCREST DR MECHANICSBURG, PA 17050 (the "Property") Dear SUSAN K WEBB: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due September 1, 2012. 2. As of March 11, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $14,224.37 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800 - 848 -9380. Total Monthly Payments $13,473.92 Late Fees $520.45 NSF Fees $0.00 Other Fees* $0.00 Advances* $230.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the telephone number provided below. 3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 4. If you fail to cure the default on or before April 15, 2013, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include; but not be limited to, allowable foreclosure /attorney fees, and other expenses permitted by your loan documents or applicable law. 5. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a default, or any other defense to acceleration and foreclosure. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. 6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800 - 848 -9380. 8. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection, the property condition, occupancy status, and possibly your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To find locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at 800 -569 -4287 or at www.hud.gov. Sincerely, Chase 800 - 848 -9380 800 -582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Important notice to servicemembers and their dependents If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888 - 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR160 An important message from the Federal Trade Commission note to Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD- certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion. free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission 1;fftc.gov/MoneyMatters Call 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD- certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www. makinghomeaffordable.gov � ! HOPENOW Support & Guidance :For - Homeowners SM MAILING HOME AFFORDABLE.GOV Chase (FL5 -7734) CHASE �' P.O. Box 44090 �� Jacksonville, FL 32231 -4090 March 11, 2013 ... IIIIIIII, IIIIIIIII11111111 00008498 HDLO ZB 7013 -BR160 SUSAN K WEBB 217 BEAVER DR MECHANICSBURG, PA 17050 -2502 Acceleration Warning (Notice of Intent to Foreclose) Account: 1547207795 (the "Loan ") Property Address: 505 WOODCREST DR MECHANICSBURG, PA 17050 (the "Property") Dear SUSAN K WEBB: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due September 1, 2012. 2. As of March 11, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $14,224.37 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800 - 848 -9380. Total Monthly Payments $13,473.92 Late Fees $520.45 NSF Fees $0.00 Other Fees* $0.00 Advances* $230.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the telephone number provided below. 3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 4. If you fail to cure the default on or before April 15, 2013, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attomey fees, and other expenses permitted by your loan documents or applicable law. 5. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a default, or any other defense to acceleration and foreclosure. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. 6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800 - 848 -9380. 8. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection, the property condition, occupancy status, and possibly your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To find locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at 800 -569 -4287 or at www.hud.gov. Sincerely, Chase 800 - 848 -9380 800 -582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Important notice to servicemembers and their dependents If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888- 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 - 550 - 5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR160 An important message from the Federal Trade Commission w note to Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD- certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion. free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission ' ftc.gov/MoneyMatters Call 1- 888 - 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD- certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www. making homeaffordable.gov t- 7. urn HOPENOW Support -& Guidance:forHomeownees �� S MAIQNG HOME AFFORDABLE.GOV Chase (FL5 -7734) CHASE P.O. Box 44090 r Jacksonville, FL 32231 -4090 7190 1075 4460 1971 7713 March 11, 2013 00008499 HDLO CB 7013 -BR160 MATTHEW WEBB 505 WOODCREST DR MECHANICSBURG, PA 17050 } Chase (FL5 -7734) P.O. Box 44090 CHASE( � Jacksonville, FL 32231 -4090 111 11111111111111111 7190 1075 4460 1971 7713 IIIIIIIIIIIIIII „III„IIIIIIII March 11, 2013 00008499 HDLO CB 7013 -BR160 MATTHEW WEBB 505 WOODCREST DR MECHANICSBURG, PA 17050 Acceleration Warning (Notice of Intent to Foreclose) Account: 1547207795 (the "Loan ") Property Address: 505 WOODCREST DR MECHANICSBURG, PA 17050 (the "Property") Dear MATTHEW WEBB: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due September 1, 2012. 2. As of March 11, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $14,224.37 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800 - 848 -9380. Total Monthly Payments $13,473.92 Late Fees $520.45 NSF Fees $0.00 Other Fees* $0.00 Advances* $230.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the telephone number provided below. 3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 4. If you fail to cure the default on or before April 15, 2013, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees, and other expenses permitted by your loan documents or applicable law. 5. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a default, or any other defense to acceleration and foreclosure. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. 6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800 - 848 -9380. 8. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection, the property condition, occupancy status, and possibly your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To fmd locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at 800 -569 -4287 or at www.hud.gov. Sincerely, Chase 800 - 848 -9380 800 -582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Important notice to servicemembers and their dependents If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888- 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR160 An important message from the Federal Trade Commission note to Homeowners _- Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD - certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion. free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission ftc.gov/MoneyMatters Call 1- 888 - 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24n — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD - certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www. making homeaffordable.gov IM =': i►nn► H 0 P f N 0 W Support & Guidance Homeowners SM MAKING HOME AFFORDABLE.GOV Chase (FL5 -7734) P.O. Box 44090 CHASE Jacksonville, FL 32231 -4090 IIIIIIIII, IIIIIIIIIIIII „IIII March 11, 2013 00008495 HDLO ZB 7013 -BR160 MATTHEW WEBB 217 BEAVER DR MECHANICSBURG, PA 17050 -2502 Acceleration Warning (Notice of Intent to Foreclose) Account: 207795 (the "Loan ") Property A dress: 505 WOODCREST DR MECHANICSBURG, PA 17050 (the "Property") Dear MATTHEW WEBB: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due September 1, 2012. 2. As of March 11, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $14,224.37 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800 - 848 -9380. Total Monthly Payments $13,473.92 Late Fees $520.45 NSF Fees $0.00 Other Fees* $0.00 Advances* $230.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the telephone number provided below. 3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 4. If you fail to cure the default on or before April 15, 2013, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure /attorney fees, and other expenses permitted by your loan documents or applicable law. 5. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a default, or any other defense to acceleration and foreclosure. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. 6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800 - 848 -9380. 8. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection, the property condition, occupancy status, and possibly your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To find locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at 800 -569 -4287 or at www.hud.gov. Sincerely, Chase 800 - 848 -9380 800 -582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Important notice to servicemembers and their dependents If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888 - 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR160 An important message from the Federal Trade Commission note to Homeowners ,YY Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop returning your calls. Others may string you along you've already gotten a delinquency notice, free help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD- certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion. free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. y Federal Trade Commission ftc.gov/MoneyMatters Call 1- 888 - 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPE TM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD- certified counseling agencies. Or visit www. hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov s. r+nn HOPENOW Support & Guidance.For Homeowners �� L S MAILING HOME AFFORDABLE.GOV Chase (FL5 -7734) CHASE I_ P.O. Box 44090 r Jacksonville, FL 32231 -4090 IIIIIIII, IIIIII „III1111„IIIII March 11, 2013 00008496 HDLO ZB 7013 -BR160 MATTHEW WEBB 505 WOODCREST DR MECHANICSBURG, PA 17050 Acceleration Warning (Notice of Intent to Foreclose) Account: 07795 (the "Loan ") Property Ress: 505 WOODCREST DR MECHANICSBURG, PA 17050 (the "Property") Dear MATTHEW WEBB: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due September 1, 2012. 2. As of March 11, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $14,224.37 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800 - 848 -9380. Total Monthly Payments $13 Late Fees $520.45 NSF Fees $0.00 Other Fees* $0.00 Advances* $230.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the telephone number provided below. 3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 4. If you fail to cure the default on or before April 15, 2013, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attomey fees, and other expenses permitted by your loan documents or applicable law. 5. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a default, or any other defense to acceleration and foreclosure. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. 6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800 - 848 -9380. 8. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection, the property condition, occupancy status, and possibly your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To find locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at 800 -569 -4287 or at www.hud.gov. Sincerely, Chase 800 - 848 -9380 800 -582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Important notice to servicemembers and their dependents If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888- 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR160 An important message from the Federal Trade Commission note to ,. Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may request hefty fees in advance —and then stop If you're having trouble paying your mortgage or returning your calls. Others may strip you've already gotten a delinquency notice, free Y g you along help is a phone call away. Call 1- 888- 995 before disclosing their charges. Cut off all dealings -HOPE if someone insists on a fee. for free personalized advice from housing counseling agencies certified by the U.S. Department Send Payments . Directl of Housing and Urban Development (HUD). Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD - certified counseling agencies. For free Don't Pay for a Second Opinion. guidance online visit www.hopenow.com. For free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission ftc.gov/MoneyMatters Call 1- 888 - 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD - certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov Support. &.Guidancefor Homeowners /1011IV/*0'V/M SM MAILING HOME AFFORDABLE.GOV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, JPMORGAN CHASE BANK, NA w Plaintiff -1 sz vs. 73 Case No. 13 , 3,) 36 r CQ C��f� MATTHEW WEBB . SUSAN K. WEBB r o c3 ; ., C_ Defendant(s) T» C—n 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: (Signature of Counsel Plamtiff) 3 Da e Cumberland County Residential Mortgage Foreclosure Diversion p�ogratn Date Financial Worksheet Cumberland County Court of Common Pleas Docket # BaRR ©WERQUE,ST POR IiARDSHIP ASSISTANCE - To complete-your request for hardship assistance, your lender roust consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: t Borrower natne(s): -- - -- Property Address: -- City: Is the property for sale? zip,: Realtor Name: Yes ON Q Listing date: price: $ Borrower Occupied? Yes No — Realtor Phone: Mailing Address (if different): City: Phone Numbers: State: zip: Come: Office: l�ma l: Cell: Other; 0 ofpeople in household: How tong? Mailing Address; City: - - Phone Numbers: ome: State: zip: H Office: Cell: Other: ther: # ofpeople in household How Jong? First Mortgage Lender: Type of Loan: Loan. Number: Second Mortgage Lender: Date You Closed Your I.oara: - Type of Loan: Loam Number: Total Mortgage Payments Amount: Date of Last Payment: Included Taxes & Insurance: Primary Reason for Default: Is the loan in Bankruptcy? Yes C] No 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �.. . FLED-OF {CE Sheriff F THE PRQTHONOTAP. �-;�r�nt!r�����d Jody S Smith 2013 JUN 14 FM 13t 05 Chief Deputy 6"1 Richard W Stewart � � WNBERLANH avWNT Y Solicitor Orr ca OF TPE IVEPWr PENNS YLVA KA JPMorgan Chase Bank, N.A. Case Number vs. 2013-3236 Matthew Webb(et al.) SHERIFF'S RETURN OF SERVICE 06/10/2013 02:42 PM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Susan Webb, Wife, who accepted as"Adult Person in Charge"for Matthew Webb at 217 Beaver Drive, Hampden Townsh' , Mechanicsburg, PA 17050. ILLIAM CLINE, DEPUTY 06/10/2013 02:44 PM - Deputy William Cline, 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: Susan K Webb at 217 Beaver Drive, Hampden Township, Mechanicsburg, PA 17050. ILLIAM CLINE, D SHERIFF COST: $55.30 SO ANSWERS, June 12, 2013 RbNt4Y R ANDERSON, SHERIFF (c)CountySuite Sheriff,Toleosoft,Inc. • In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13-3236 CIVkL.) rY? C. „.a VS. ;...- .. MATTHEW WEBB -.3 c 1,,;- SUSAN K.WEBB in,-� c� '',T ' (Mortgagor(s)and Record Owner(s)) v�- 0',t 505 Woodcrest Drive ........% `.,=` Mechanicsburg,PA 17050 tr c" Mechanicsburg, Defendant(s) Y> "' - ; °; Z cp'3� --- PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against MATTHEW WEBB and SUSAN K. WEBB by default for want of an Answer. Assess damages as follows: $288,612.71 Debt Interest from 4/1/2013 to Date of Sale per diem at$36.32 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the 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.j By: KML LAW OUP,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.Gomall Pa.ID 92382 Attorneys for Plaintiff �� (; `A..k % v/ 1 � TG -/b /`I/ a[ AND NOW LI c;` , 06 7 g ,Judgment is entered in favor of JPMORGAN CHASE BANK,NA and against MATTHEW WEBB and SUSAN K. WEBB by d It fotof an Answer and damages assessed in the sum of$288,612.71 as per the above certification. Ali Prothonotary 1111► ._ 47S/o3S- Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13-3236 CIVIL vs. MATTHEW WEBB SUSAN K.WEBB (Mortgagors and Record Owner(s)) 505 Woodcrest Drive Mechanicsburg,PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cum land C ty 1 Courthouse Square A Carlisle,PA 17013 i° ' By: Deputy IQStl3 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 • 121350FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 11,2013 TO: MATTHEW WEBB 505 Woodcrest Drive Mechanicsburg,PA 17050 In the Court of • JPMORGAN CHASE BANK,NA Common Pleas 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff VS. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K.WEBB Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 505 Woodcrest Drive Mechanicsburg,PA 17050 No. 13-3236 CIVIL Defendant(s) TO: MATTHEW WEBB 505 Woodcrest Drive Mechanicsburg,PA 17050 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 WRING 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: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puke Pa.ID 27615 /Jill P.Jenkins Pa.1D 306588 Alyk L.Oflazian Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 121350FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 11,2013 TO: SUSAN K.WEBB 505 Woodcrest Drive Mechanicsburg,PA 17050 In the Court of JPMORGAN CHASE BANK,NA Common Pleas 3415 Vision Drive of Cumberland County Columbus,OI l 43219 Plaintiff vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K.WEBB Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 505 Woodcrest Drive Mechanicsburg,PA 17050 No. 13-3236 CIVIL Defendant(s) TO: SUSAN K.WEBB 505 Woodcrest Drive Mechanicsburg,PA 17050 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 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: KML LAW G OUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Till P.Jenkins Pa.1D 306588 jAlyk L.Oflazian Pa.ID 312912 Michael J.Coskey Pa 1D 311835 215-627-1322 Attorneys for Plaintiff 121350FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 11,2013 TO: MATTHEW WEBB 21.7 Beaver Drive Mechanicsburg,PA 17050 JPMORGAN CHASE BANK,NA In mmoon n Pleas Comls 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaint vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K.WEBB Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 505 Woodcrest Drive Mechanicsburg,PA 17050 No. 13-3236 CIVIL Defendant(s) TO: MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 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 TILE 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,TIES OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS Al'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: 61\i KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fcin Pa.ID 82628 Thomas Puleo Pa.ID 27615 1 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 121350FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 11,2013 TO: SUSAN K WEBB 217 Beaver Drive Mechanicsburg,PA 17050 In the Court of JPMORGAN CHASE BANK,NA Common Pleas 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff Vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K,WEBB Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 505 Woodcrest Drive Mechanicsburg,PA 17050 No. 13-3236 CIVIL Defendant(s) '1'O: SUSAN K WEBB 217 Beaver Drive Mechanicsburg,PA 17050 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH 113E COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS Al'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 LAWGROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NA Plaintiff vs. MATTHEW WEBB NO. 13-3236 CIVIL SUSAN K.WEBB Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): MATTHEW WEBB, has a last known residence of 217 Beaver Drive, Mechanicsburg, PA 17050. 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. Date /6 By: KML LAW GR UP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Oct-23-2013 12:49:23 SCRA 3.0 Starts Report -' R s 'e Pursuant to Servicemenibeers Civil Relief Act Last Name: WEBB First Name: MATTHEW Middle Name: Active Duty Status As Of: Oct-23-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuale active duty status based on the Active Duty Status Date Left Active Duty.Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component. NA NA No NA This response reflects whether the individual or his/tier unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOM 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: G5K98E42D059340 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NA ' Plaintiff vs. MATTHEW WEBB NO. 13-3236 CIVIL SUSAN K.WEBB Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): SUSAN K. WEBB, has a last known residence of 217 Beaver Drive, Mechanicsburg, PA 17050. 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. Date (Le By: KML LAW GRO P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornal l Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 tll P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa.ID 312912 Attorneys for Plaintiff Results as of:Oct-23-2013 12:52:24 Department of Defense Manpower Data Center SCRA 3.0 � g ` Status Report Pursuant to Servicemembers Civil Relief Act Last Name: WEBB First Name: SUSAN Middle Name: K. Active Duty Status As Of: Oct-23-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active •Duty Start Date Active Duty End Date Status Service Component'. NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component. NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. �+ a Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPM). 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: 35E55E92H05A680 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,NA c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 Plaintiff of Cumberland County vs. MATTHEW WEBB CIVIL ACTION LAW SUSAN K.WEBB (Mortgagor(s)and Record owner(s)) 505 Woodcrest Drive ACTION OF MORTGAGE FORECLOSURE Mechanicsburg,PA 17050 Defendant(s) No. 13-3236 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK,NA,and against MATTHEW WEBB and SUSAN K. WEBB 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$288,612.71. By: KML LAW GROUP,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 „/1!`��— is j ,403)0 I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive Columbus,OH 43219 and that the name(s)and last known address(es)of the Defendant(s)is/are MATTHEW WEBB,217 Beaver Drive Mechanicsburg,PA 17050 and SUSAN K. WEBB,217 Beaver Drive Mechanicsburg,PA 17050; By: KML LAWOUP,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 /417 IL . 0/(GI 2i /O ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $271,927.53 Interest from 08/01/2012 through $8,837.68 03/31/2013 Reasonable Attorney's Fee $1,650.00 Accrued Late Charges $669.15 Property Preservation $160.00 Property Inspections $98.00 Escrow Advance $5,270.35 $288,612.71 By: KML LAW GR 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.Gomall Pa.ID 92382 Attorneys for Plaintiff A L 004vt-4/, AND NOW,this day of U ,2013 d ages are assessed as above. (3)[9.f u Pro Prothy 13-3236 CIVIL/121350FC r 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,NA c/o 3415 Vision Drive Columbus,OH 43219 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County MATTHEW WEBB CIVIL ACTION—LAW SUSAN K.WEBB Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 505 Woodcrest Drive Mechanicsburg,PA 17050 Defendant(s) No. 13-3236 CIVIL ' ' rn co d T- c i t r— PRAECIPE FOR WRIT OF EXECUTION o ` '_7 'ter .. -mot:,' TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $288,612.71 Interest from 4/1/2013 to Date of Sale per diem at$36.32 (Costs to be added) avx-1 5s. 3v KML LAW GROUP,P.C. 1 c%, S 1 t Michael McKeever Pa.ID 56129 (k i{ Jay E.Kivitz Pa.ID 26769 rJ� Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 1d '05 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 g a as (Attorneys for Plaintiff -16 67PA (Lig 79-1w-41,4- /-0 34) 9/`41 bic1737 I �l rt �- o� 12E .ccsi/ecf fr r 0 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street E P R O T H O a O Tr A Philadelphia,PA 19106 215-627-1322 2813 OCT 25 PH 1: 12 Attorney for Plaintiff .HHMVFRI AND COUNTY JPMORGAN CHASE BANK,NA PEN 2 S Y LVA Pd!A do 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 Plaintiff of Cumberland County vs. MATTHEW WEBB CIVIL ACTION-LAW SUSAN K. WEBB (Mortgagor(s)and Record Owner(s)) 505 Woodcrest Drive ACTION OF MORTGAGE FORECLOSURE Mechanicsburg,PA 17050 Defendant(s) No. 13-3236 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NA,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: 505 Woodcrest Drive Mechanicsburg,PA 17050 1.Name and address of Owner(s)or Reputed Owner(s): MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 SUSAN K. WEBB 217 Beaver Drive Mechanicsburg,PA 17050 2.Name and address of Defendant(s)in the judgment: MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 SUSAN K.WEBB 217 Beaver Drive Mechanicsburg,PA 17050 • K • 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 505 Woodcrest Drive Mechanicsburg,PA 17050 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: /9/2 Z /—° By KML LA GROUP,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 L 61/1/A-z-74-44/ 1/ Cl 13-3236 CIVIL iLE3 f riri _, KML Law Group,P.C. J 4�I I r P P O T t O N U T', Suite 5000-BNY Independence Center 701 Market Street :D13 OCT 25 PM 1: 12 Philadelphia,PA 19106 (215)627-1322 CUMBERLAND COUNTY Attorney for Plaintiff PEN S Y i JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K. WEBB ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 505 Woodcrest Drive Mechanicsburg,PA 17050 Docket No. 13-3236 CIVIL Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WEBB,MATTHEW MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 Your house at 505 Woodcrest Drive,Mechanicsburg,PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday,March 05,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$288,612.71 obtained by JPMORGAN CHASE BANK,NA against you. N OTICE 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,NA,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. 13-3236 CIVIL 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 fmd 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 13-3236 CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 121350FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-3236 CIVIL K1VIL Law Group,,P.C. ri,E y 37'HCIN.J�; Suite 5000-BNY Independence Center 701 Market Street 2213 OCT 2 5 PH f: 12 Philadelphia,PA 19106 (215)627-1322 a;UMBERLANO COUNTY Attorney for Plaintiff PENNSYLVANIA JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus, OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K. WEBB ACTION OF MORTGAGE Mortgagor(s) and Record Owner(s) FORECLOSURE 505 Woodcrest Drive Mechanicsburg,PA 17050 Docket No. 13-3236 CIVIL Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WEBB,SUSAN K. SUSAN K. WEBB 217 Beaver Drive Mechanicsburg,PA 17050 Your house at 505 Woodcrest Drive,Mechanicsburg,PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday,March 05,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$288,612.71 obtained by JPMORGAN CHASE BANK,NA 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,NA,the back payments, late charges, costs and reasonable attorney's fees due.To fmd 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. 13-3236 CIVIL 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 fmd 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 i 1 13-3236 CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender)at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention!,kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 121350FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group,P.C. r .1 Suite 5000—BNY Independence Center t - 1-1"*.' i `� '`' 701 Market Street 3 Philadelphia,PA 19106 7213 OCI 25 215-627-1322 Attorney for Plaintiff CC MB RL A'AD C Q W,I JPMORGAN CHASE BANK,NA do 3415 Vision Drive Columbus, OH 43219 IN THE COURT OF Plaintiff COMMON PLEAS vs. of Cumberland County MATTHEW WEBB SUSAN K.WEBB CIVIL ACTION-LAW Mortgagor(s)and Record Owner(s) 505 Woodcrest Drive ACTION OF Mechanicsburg,PA 17050 MORTGAGE FORECLOSURE Defendant(s) NO. 13-3236 CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: ‘'.)17 KML LAW GR 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 /4/y6. ( 0-fia 7d 0 I� qra WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3236 Civil COUNTY OF CUMBERLAND) CIVIL ACTION–LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NA Plaintiff(s) From MATTHEW WEBB,SUSAN K. WEBB (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $288,612.71 L.L.: $.50 Interest FROM 4/1/2013 TO DATE OF SALE PER DIEM AT$36.32 Atty's Comm: Due Prothy: $2.25 Atty Paid: $204.05 Other Costs: Plaintiff Paid: Date: 10/25/13 —12444:14.M.Rea.Z.L, David D. B,ell, Prothonota , (Seal) e : Deputy REQUESTING PARTY: Name: ALYK L.OFLAZIAN,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. 310912 KML LAW GROUP,P.C. 121350FC Suite 5000 �= CF: 06/06/2013 tJr IL . j� l:;�^�' SD: 03/12/2014 BNY Mellon Independence Center Hit j- , t 701 Market Street 0NO j .i(,: $288,612.71 Philadelphia,PA 19106-1532 2014 FEB i J UU 'iii (a�, 215-627-1322 : 27 Attorne for Plaintiff 1uER JPMORGAN CHASE BANK,NA a SYLV-Sr". eOURT OF COMMON PLEAS do 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION—LAW MATTHEW WEBB ACTION OF MORTGAGE FORECLOSURE SUSAN K. WEBB Mortgagor(s)and Term Record Owner(s) - No. 13-3236 CIVIL 505 Woodcrest Drive Mechanicsburg,PA 17050 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c)(2) Veronica Cosine, an employee of KML Law Group,P.C., counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) 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). (X) 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, ItiON BY: Veronica Cosme Legal Assistant • Sue Webb 717-737-6567 p.3 KML Law Group,P.C. SUITE 5000—BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106-1532 (215)627-1322 BY: MICHAEL T.MCKEEVER,ESQUIRE ATTORNEY I.D.456129 ATTORVEY FOR PLAINTII F JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive Columbus,OH 43219 IN THE COURT OF COMMON Plaintiff PLEAS OF Cumberland COUNTY vs. CIVIL ACTION -LAW MATTHEW WEBB SUSAN K. WEBB Term 505 Woodcrest Drive No. 13-3236 CIVIL Mechanicsburg, PA 17050 Defendant(s) ACCEPTANCE OF SERVICE I accept service of the Notice of Sale in Mortgage Foreclosure on behalf of Defendant(s) MATTHEW WEBB and certify that I am authorized to do so. Date: i I/a 543 /I� MATTHEW WEBB Sue Webb 717-737-6567 p.2 KML Law Group,P.C. SUITE 5000—BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106-1532 (215)627-1322 BY: MICHAEL T.MCKEEVER,ESQUIRE ATTORNEY I.D.#56129 ATTORWEY FOR PLAINTIFF JPMORGAN CHASE BANK,NA c/o 3415 Vision Drive Columbus, OH 43219 IN THE COURT OF COMMON Plaintiff. PLEAS OF Cumberland COUNTY vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K.WEBB Term 505 Woodcrest Drive No. 13-3236 CIVIL Mechanicsburg,PA 17050 Defendant(s) ACCEPTANCE OF SERVICE I accept service of the Notice of Sale in Mortgage Foreclosure on behalf of Defendant(s) SUSAN K. WEBB and certify that I am authorized to do so. Date: 1 1/2.S-/!.3C�zGel] L1L/..r�� SUSAN K.WEBB • Name and Address of Sender Check type of mall or service; Affix Stamp Here • KML LAW GROUP,P.C. (if Issued sue SUITE 5000 ❑Certified ❑ Recorded Delivery(International) certificate of mailing, gqP. ❑COD ❑ Registered or for additional copies 701 MARKET STREET ❑ Delivery Confirmation ❑ Retum Receipt for Merchandise of this bile PHILADELPHIA,PA ❑ Express Mall ❑Signature Confirmation Postmark and ,yt �,*,•• iv. +iRY BOWS 19106-1532 I Insured Date of Receipt w; 3p Handling� ''' '�• 00020142485951 00.20° Article Number Addressee(Name,Street,City,Slate,&ZIP Code) Postage Fee one .MAILED FROM ZIP CODE 19100 6 Fee 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY . PO Box 320 TENANTS/OCCUPANTS Carlisle,PA 17013 505 Woodcrest Drive 1 Mec.liankabutg,- A 17050 2' PA DEPARTMENT OF PUBLIC WELFARE- %, _ Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 ' 3. Harrisburg,PA 17105-2875 1 { 4. • •• 5 - i 6. •\� `�, +l , 7' 8. tl Total Number of Pi-• I Total Number of Pistils Postmaster,Pet,(Nof receiving employee) Listed by Sender Received at Post Of/ t 1111``////rte//�_ See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page 1 of 2) • Complete by Typewriter,Ink,or Ball Point Pen • 121350FC Cumberland County Sale Date:03/12/2014 MATTHEW WEBB&SUSAN K.WEBB 5.4.S • 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,NA IN THE COURT OF COMMON PLEAS do 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW MATTHEW WEBB SUSAN K.WEBB ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) Term 505 Woodcrest Drive No. 13-3236 CIVIL Mechanicsburg,PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NA,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: 505 Woodcrest Drive Mechanicsburg,PA 17050 1.Name and address of Owner(s)or Reputed Owner(s): MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 SUSAN K. WEBB 217 Beaver Drive Mechanicsburg,PA 17050 2.Name and address of Defendant(s)in the judgment: MATTHEW WEBB 217 Beaver Drive Mechanicsburg,PA 17050 SUSAN K. WEBB 217 Beaver Drive Mechanicsburg,PA 17050 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 505 Woodcrest Drive Mechanicsburg,PA 17050 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: February 17,2014 'Jr L Law Group,P.C. BY: Veronica Cosme Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;-vF F"1r Sheriff OF THE PROT i:F ;O' ir:.;, Jody S Smith Chief Deputy 2014 MAY -6 PM 2, j I Richard W Stewart '" CUMBERLAND COUNTY Solicitor . CARCr s $ rR' r' PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. Matthew Webb (et al.) 2013-3236 SHERIFF'S RETURN OF SERVICE 01/08/2014 11:44 AM - Deputy Valerie Weary, 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 505 Woodcrest Drive, Hampden -Township, Mechanicsburg, PA 17050, Cumberland County. 03/12/2014 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Michael McKeever, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $804.15 SO ANSWERS, April 08, 2014 RONNYR ANDERSON, SHERIFF �fS= dU pot- R-(2.5- poi Lz . ea- 1 9s- c)Cio.ntvSu:ie Sheriff.ieleoso t.Inc. On November 18, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 505 Woodcrest Drive, c._ o W Mechanicsburg, as Exhibit "A" filed with this writ and by Cr)a _) «this Reference incorporated herein. �rz: WCY C=J r,.y mate: November 18, 2013 By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No.2013-3236 Civil Term JPMorgan Chase Bank,N.A vs. Matthew Webb Susan K.Webb Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 505 Wood- crest Drive, Mechanicsburg, PA 17050. SOLD as the property of MAT- THEW WEBB and SUSAN K.WEBB. TAX PARCEL#10-17-1033-164. 80 la ` 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: January 24, January 31, and February 7, 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. )4/ : Lisa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 C:2).-eZtet.gd. fred Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 2B,2014 the Patriot-News Co. • 20 Technology Pkwy • e atriot4kws MechaniebUrg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 2013-3236 Civil Term 01/19/14 JPMorgan Chase Bank, 01/26/14 N.A Vs r , 02/02/14 i rP Matthew Webb Susan K Webb Atty: Michael McKeever IMPROVEMENTS consist of a Swor to and subscribed before me t 1 a of Februa , 2014 A.D. residential dwelling. [ 1 I BEING PREMISES: 505 Woodcrest I '-� ( 1 Drive,Mechanicsburg,PA 17050 �� _ A6.-. SOLD as the property of MATTHEW 'UT"' WEBB and SUSAN K.WEBB TAX PARCEL#10-17-1033-164 C,OMMi7i PENIA ^ ' _ Notarial OF Seal Hotly Lynn Warfel,Notary.WEBB n WashingtOn TwP.,bras Dec.CCoou , My Commission Exp MEMBER PENNSYLVPNtA a«nCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Natl Mtg Assoc is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 25th day of October, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3236, at the suit of JPMorgan Chase Bank against Matthew & Susan K Webb is duly recorded as Instrument Number 201409322. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this (0 day of _7E13r_, A.D. off-0/z( 4-) 7),b Recorder of Deeds Recor i Deeds,Cumberland County,Carlisle,PA My Co mission Expires the First Monday of Jan.2018 • • /