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Home My WebLink About13-3418 Supre me Court of Pennsylvania Couit%f i u o'i! ran Pleas C S C €iCel S eet ForProdionotarr Use Onh Cumberland v - COutttl` Docket : The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiling and service ofpleadings or other papers as required by law 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 ANDY F. RUSSELL C TIFFANY M. WILSON T` i Dollar Amount Requested within arbitration limits 0 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 ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: Q .' MASS TORT ❑Other ❑ Asbestos -_- ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort -Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration ❑Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CI N -T 701 MARKET STREET s " PHILADELPHIA, PA 19106 � ,, 3 yP, (866) 413 - 2311 7 ` WW`"'. KMLLAWGR0UP.00M JPMORGAN CHASE BANK, NA IN THE COURT OF COMMON PLEAS 3415 Vision Drive Columbus, OH 43219 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION - LAW ANDY F. RUSSELL TIFFANY M. WILSON ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 1495 Longs Gap Road Carlisle, PA 17013 CWT, AL�fI�N. MORTGAGI Defendant(s) FG�CLOSM 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) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. 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 LLAM POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA S AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. P"g14a 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.aTxx 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.philadell2hiafed.org /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentiongkmllawgroup.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 121793FC. 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, 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are ANDY F. RUSSELL, 1495 Longs Gap Road, Carlisle, PA 17013 and TIFFANY M. WILSON, 1495 Longs Gap Road, Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On May 13, 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 May 14, 2010 as Instrument #201012353. 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 February 01, 2013 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 May 23, 2013: Principal Balance ..................................... ............................... ....................$166,736.75 Interest from 01/01/2013 through 04/30/2013 ....................... ......................$3,056.84 AccruedLate Charges .................................. ............................... .........................$78.74 Property Inspections ..................................... ............................... .........................$70.00 EscrowBalance ................................................................. ............................... ($428.40) Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $171,163.93 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. Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $171,163.93, 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 a d s of the mortgage property. By: KML L O , P. . Micha' 1 McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 -Mill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Pennsylvania Verification STEFAN HEARST , hereby states that ashe is Vice President of JPMorgan Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. STEFAN HEARST Vice President Date: 05/31/13 JPMorgan Chase Bank, N.A Borrower: ANDY RUSSELL and TIFFANY WILSON Property Address: 1495 LONGS GAP ROAD, CARLISLE, PA 17013 County: CUMBERLAND Last Four of Loan Number: 0194 Ex,hibit A Exhibit "A" (legal description) ALL THAT CERTAIN lot of ground situate in the Township of North Middleton, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the eastern line of the Long's Gap Road and at the line of property, now or formerly of Sherwood Schlusser; thence in a northerly direction along the said road, one hundred (100) feet to a point at the line of land, now or formerly of Harold E. Schlusser and Mabel P. Schlusser, his wife; thence in an easterly direction along land, now of formerly, of the said Schlusser, four hundred seventy -eight (478) feet to a point at the line of land now or formerly of William Brownawell; thence in a diagonal direction along the fence line between property now or formerly of the said Brownawell and the lot herein described, a distance of three hundred twenty (320) feet to a point in the line of property, now or formerly of Sherwood Schlusser; thence in a northerly direction along land now or formerly of Sherwood Schlusser, a distance of one hundred twelve (112) feet to a point; thence in a westwardly direction along the same, a distance of three (300) feet to a point in the eastern line of the Long's Gap Road, the place of BEGINNING. BEING THE SAME PREMISES which Nancy C. Monismith, single woman, by Deed dated May 13, 2010, and intended for recording immediately prior hereto in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, granted and conveyed to Andy F. Russell and Tiffany M. Wilson. Ey�,h *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5 -7734) CHASE P.O. Box 44090 C� Jacksonville, FL 32231 -4090 7190 1075 4460 2077 4293 April 3, 2013 00004140 HDLO CC 9413 -BR860 ANDY F RUSSELL 1495 LONGS GAP RD CARLISLE, PA 17013 Chase (FL5 -7734) CHASE P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 2077 4293 April 3, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00004140 HOLO CC 9413 -BR860 ANDY F RUSSELL 1495 LONGS GAP RD CARLISLE, PA 17013 Act 91 Notice Account: _ 194 (the "Loan ") Property Address: 1495 LONGS GAP RD CARLISLE, PA 17013 (the 'Property") Dear ANDY F RUSSELL: On the following page, you will find a notice regarding your home as required by Pennsylvania law. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If von have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at 800- 342 -2397. (Persons with impaired hearing can call 717- 780 - 1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): ANDY F RUSSELL TIFFANY M WILSON PROPERTY ADDRESS: 1495 LONGS GAP RD CARLISLE, PA 17013 LOAN ACCOUNT NUMBER: 1876660194 ORIGINAL LENDER: JPMORGAN CHASE BANK, N.A. CURRENT LENDEWSERVICER: JPMorgan Chase Bank, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICA TION AS SOON AS POSSIBLE IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY (3 0) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FR OM S TA R TING A FORE CL OS URE A CTION A GA INS T YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Tiled bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at: 1495 LONGS GAP RD, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 02/01/2013 $1,200.39 03/01/2013 $1,200.39 04/01/2013 $1,200.39 Other charges: Late Charges: $39.37 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $56.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $3,696.54 HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,696.54, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check, certified check or money order made payable and sent to Overnight /Regular Mail: Chase Mail Code: 01-14 -7133 3415 Vision Drive Columbus, OH 43219 -6009 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) -DAY period, von will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anytime up to one hour before the Sheriff's Sale. You may do so by paving the total amount then past due plus anylate or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Chase Address: Mail Code: OH4 -7384 3415 Vision Drive Columbus, OH 43219 Telephone Number: 800 - 848 -9380 Fax Number: 614 - 5004605 Contact Person: Bruno Mejia E -mail Address: state .programs.intake @jpmchase.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Advantage Credit Counseling Service /CCCS of 888- 511 -2227 2000 Linglestown Road Harrisburg 17102 Western PA Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104 Region Housing Alliance of York/Y Housing Resources 717- 855 -2752 290 West Market Street York 17401 Maranatha 717- 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717 -334 -1518 40 E. High Street Gettysburg 17325 Inc. PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110 800 -342 -2397 Rev. 10/12 FM646 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. 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 877 - 469 -0110. 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 - 995 -4673. 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. BR860 Chase (FL5 -7734) CHASE P.O. Box 44090 Jacksonville, FL 32231 -4090 April 3, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00004141 HDLO ZB 9413 -BR860 TIFFANY M WILSON 1495 LONGS GAP RD CARLISLE, PA 17013 Act 91 Notice Account: _ 194 (the "Loan ") Property Address: 1495 LONGS GAP RD CARLISLE, PA 17013 (the "Property ") Dear TIFFANY M WILSON: On the following page, you will fmd a notice regarding your home as required by Pennsylvania law. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons with impaired hearing can call 717 - 780 - 1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): ANDY F RUSSELL TIFFANY M WILSON PROPERTY ADDRESS: 1495 LONGS GAP RD CARLISLE, PA 17013 LOAN ACCOUNT NUMBER: 1876660194 ORIGINAL LENDER: JPMORGAN CHASE BANK, N.A. CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YO U SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YO U HA VE A MEETING WITH COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date). NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at: 1495 LONGS GAP RD, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 02/01/2013 $1,200.39 03/01/2013 $1,200.39 04/01/2013 $1,200.39 Other charges: Late Charges: $39.37 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $56.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $3,696.54 HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,696.54, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check certified check or money order made payable and sent to Overnight /Regular Mail: Chase Mail Code: 01-14 -7133 3415 Vision Drive Columbus, OH 43219 -6009 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) -DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so by paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff s Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Chase Address: Mail Code: 0114 -7384 3415 Vision Drive Columbus, 01143219 Telephone Number: 800 -848 -9380 Fax Number: 614 - 5004605 Contact Person: Bruno Mejia E -mail Address: state.programs.intake @ jpmchase.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Advantage Credit Counseling Service /CCCS of 888- 511 -2227 2000 Linglestown Road Harrisburg 17102 Western PA Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104 Region Housing Alliance of York/Y Housing Resources 717 - 855 -2752 290 West Market Street York 17401 Maranatha 717- 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717- 334 -1518 40 E. High Street Gettysburg 17325 Inc. PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110 800 -342 -2397 Rev. 10/12 FM646 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. 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 877 - 469 -0110. 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 - 995 -4673. 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. BR860 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NA r Plaintiff vs. Case No. ANDY F. RUSSELL TIFFANY M. WILSON ° f— Defendant(s) - NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Resp*ud (Sigaintiff) Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete -your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: E�M - M 14 1 a W a Borrower narne(s): Property Address: City: - State: Zip:. Is the property for sale? Yes E No ❑ Listing date: Price: S Realtor Name: Realtor Phone: Borrower Occupied' Yes L7 No Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: Stage: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: Hove long? -- FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: hate You Closed Your Uan Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes E] No if yes, provide names, location of cmirt, case number & attorney: Assets A rnOlitxt Owed Value: Home:. $ $ Other Real Estate: $ - ; Retirement Funds: $ $ Investments: $ Checking: $ $ Savings: $ $ Other: $ $ Automobile 41: Model: Year: Amount owed: Value: Automobile #2 : Model Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): I . monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2` Mortgage Utilities f Car Pa ens Condo/Nei . Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su rt/Alim. Spendip Mone Da f /Child Gare/Tuit, Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? yes 0 No D If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No U If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes [] No If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Marne): Phone: Servicing Company (Name): Contact: Phone: Me, , authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Y Proof of income Past 2 bank statements Y Proof of any expected income for the last 45 days Y Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY - Ronny R Anderson I`!LED-OFFICE Sheriff r Or` THE PROTHONOTARY Jody S Smith Chief Deputy 2013 JUN 26 PM -2-- -12 Richard W Stewart Solicitor OPFICE OF TPE SYEFOrr CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. Andy Franklin Russell (et al.) 2013-3418 SHERIFF'S RETURN OF SERVICE 06/24/2013 05:20 PM-Deputy Noah 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:Tiffany May Wilson at 1495 Longs Gap Road, North Middleton, Carlisle, PA 17013. NOAH CLINE, DEPUTY 06/24/2013 05:20 PM-Deputy Noah 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 Tiffany May Wilson, Fiancee of defendant, who accepted as"Adult Person in Charge"for Andy Franklin Russell at 1495 Longs Gap Rd, North Middleton, Carlisle, PA 17013. NOAH CLINE, DEPUTY SHERIFF COST: $50.78 SO ANSWERS, June 25, 2013 RONW FANDERSON, SHERIFF (0)CouraySulle sheriff,Teleosoft,Inc. In the Court of Common Pleas of Cumberland County rn JPMORGAN CHASE BANK,NA � i=� 3415 Vision Drives Columbus,OH 43219 -� ...r'�"' Plaintiff No. 13-34 u8 VS. J,C3 °^•C"7 ANDY F.RUSSELL ?o t- TIFFANY M.WILSON , (Mortgagor(s)and Record Owner(s)) 1495 Longs Gap Road Carlisle,PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against ANDY F.RUSSELL and TIFFANY M.WILSON by default for want of an Answer. Assess damages as follows: $171,163.93 Debt Interest from 5/1/2013 to Date of Sale per diem at$25.12 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.237.1 By. KML LAW GROUP _Michael McKeever P . 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 C 1 yS Joshua I.Goldman Pa.205047 _Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 - Aft rnreys for Plaintiff Id AND NOW �p x a` �`� _ Judgent is entered in favor of JPMORGAN CHASE BANK,NA Ad against ANDY F.RUSSE and TIFFANVV. WNQON boardekult for want Answer and damages assessed in the sum of$171,163.93 as per the above certificati . f Prot4pnot w<e " Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW JPMORGAN CHASE BANK,NA 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13-3418 vs. ANDY F.RUSSELL TIFFANY M. WILSON (Mortgagors and Record Owner(s)) 1495 Longs Gap Road Carlisle,PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthous quare Carlisle,PA 1 13 Prothonotary By: w�" r Deputy If you have any questions concerning the above,please contact: KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Qt�tti+� ulisCr4a Chief Deputy Richard WStewart Solicitor OFf Ce-�THE sh5rF:FF JPMorgan Chase Bank, N.A. vs. Case Number Andy Franklin Russell (et al.) 2013-3418 • i SHERIFF'S RETURN OF SERVICE 06/24/2013 05:20 PM-Deputy Noah 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:Tiffany May Wilson at 1495 Longs Gap Road, North Middleton, Carlisle, PA 17013. NOAH CLINE, DEPUTY 06124/2013 05:20 PM-Deputy Noah 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 Tiffany May Wilson,Fiancee of defendant,who. . accepted as"Adult Person in Charge"for Andy Franklin Russell at 1495 Longs Gap Rd, North Middleton, Carlisle, PA 17013. NOAH CLINE, DEPUTY SHERIFF COST:$50.78 SO ANSWERS, D June 25, 2013 RONNY R ANDERSON, SHERIFF i j i (cP Caurtrsuite snwit(,Tdeosoa_mc. 121793FC 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: Daly 15,2013 TO: ANDY F.RUSSELL 1495 Longs Gap Road Carlisle,PA 17013 JPMORGAN CHASE BANK,NA In the Court of Common Pleas 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plainly vs. CIVIL ACTION-LAW ANDY F.RUSSELL TIFFANY M.WILSON Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 1495 Longs Gap Road Carlisle,PA 17013 No. 13-3418 Defendant(v) TO: ANDY F.RUSSELL 1495 Longs Crap Road Carlisle,PA 17013 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 RvIPORTANT 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 WITII INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLANn COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 C� By:. KML LAW UOUP,P.C. Michael McKeever Pa.1D 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 31.1.835 215-627-1322 Attorneys for Plaintiff 121793FC 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: July 1.5,2013 TO: TIFFANY M.WILSON 1495 Longs Crap Road Carlisle,PA 17013 In the Court of JPMORGAN CHASE BANK,NA Common Pleas 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff' VS. CIVIL ACTION-LAW ANDY F.RUSSELL TIFFANY M. WILSON Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 1495 Longs Gap Road Carlisle,PA 17013 No. 13-3418 Defendant(s) TO: TIFFANY M.WILSON 1495 Longs Gap Road Carlisle,PA 17013 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 S3-RVICFS INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KM L 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 T omas Pulco Pa.ID 27615 2 ill P.Jenkins Pa.ID 306588 Alyk L.Otlaziau Pa.ID 312912 Michael L 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. ANDY F.RUSSELL NO. 13-3418 TIFFANY M.WILSON Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEM 3ERS 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 (bttps://wvrvN,.dmdc.osd.mil/appi/scra/scraHome.do) for the following individual(s): ANDY F. RUSSELL, has a last known residence of 1495 Longs Gap Road, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): Last Name X First Name X_Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date & Z By: . KML LAW GROUP,P.0 Michael McKeever Pa. 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 X Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department Of Defense Manpower Data Center Results as of:Aug-02-20,309:22:24 SCRA 3.0 r status Report Yf Pursuant to Servicememben Civil.Relief Act- Last Name: RUSSELL First Name: ANDY Middle Name: F. Active Duty Status As Of: Aug-02-2013 On Alive Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,A, No k 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 lStatus Date Active Duty Stan Date Active Duty End Date Status Service Component NA NA is .f 7 No 7, NA This response reflects where the indMdual 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 S 'w''. .. � No NA This response reflects whether the indiv ituai or hlsfier 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:hftp://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 maybe invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: K3SDS88FUOEET40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA. JPMORGAN CHASE BANK.,NA Plaintiff vs. ANDY F.RUSSELL NO. 13-3418 TIFFANY M.WILSON 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://ww",.dmde.osd.mil/appj/scra/scraHome.do) for the following individual(s): TIFFANY M. WILSON, has a last known residence of 1495 Longs Gap Road, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date h� > By: , , KML LAW GROUP,P. . Michael McKeever IFAD 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 L Goldman Pa. ID 205047 Salvatore Filippello Pa.ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-02-2013 09:25:03 SCRA 3.0 f Stan s ReprJirt :. ' ' Pursuant to Service-members, evil Relief Act. Last Name: WILSON First Name: TIFFANY Middle Name: M. Active Duty Status As Of: Aug-02-2013 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 individuate'active duty status based on the Active Duty Status Date Leff Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA r NA \.._} .r. �• •.. .No- NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date Y , I 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.. 'N . +.!. No NA This response reflects whether the individual oY hlsthi'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. 4 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 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.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 maybe invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 13CB18CF80EFL50 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 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 Plaintiff of Cumberland County vs. ANDY F.RUSSELL CIVIL ACTION LAW TIFFANY M. WILSON (Mortgagor(s)and Record owner(s)) 1495 Longs Gap Road ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 13-3418 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK,NA,and against ANDY F.RUSSELL and TIFFANY M. WILSON 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$171,163.93. By: KML LAC.Michael 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff x 544, c,rc, r—,'t, to 313��T I hereby certify that the above names are correct and that the precise reside address of the judgment creditor is JPMORGAN CHASE BANK,NA 3415 Vision Drive Columbus,OH 43219 and that the name(s)and last known address(es) of the Defendant(s)is/are ANDY F.RUSSELL, 1495 Longs Gap Road Carlisle,PA 17013 and TIFFANY M.WILSON, 1495 Longs Gap Road Carlisle,PA 17013; By: KML LAW GRO Michael McKeev a.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff x Salvatare. F, P (C) ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $166,736.75 Interest from 01/01/2013 through $3,056.84 04/30/2013 Reasonable Attorney's Fee $1,650.00 Late Charges $78.74 Property Inspections $70.00 Escrow ($428.40) $171,163.93 By: KML LAW GROUP, Michael McKeever Pa. 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 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff X SaivoVM rills <O 313k�7 AND NOW,this day of ,2013 damages re assessed as of e. Pro Prothy 13-3418/121793FC PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSVQ) � P.R.C.P 3180-3183 KML Law Group,P.C. CD Suite 5000-BNY Independence Center C-) 701 Market Street Philadelphia,PA 19106 215-627-1322 --e- Attorney for Plaintiff JPMORGAN CHASE BANK,NA 3415 Vision Drive Columbus,OH 43219 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County ANDY F.RUSSELL CIVIL ACTION—LAW TIFFANY M.WILSON Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 1495 Longs Gap Road Carlisle,PA 17013 Defendant(s) No, 13-3418 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $171,163.93 Interest from 5/1/2013 to Date of Sale per them at$25.12 (Costs to be added) By: KML LAW GROUP, Ard? SOM Michael McKeever Pa 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 s� �, ' � F tto 3 (3 01 �� rl �- � 0111" Ll No. 13-3418 IN THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK,NA vs. ANDY F.RUSSELL and TIFFANY M.WILSON (Mortgagor(s)and Record Owner(s)) 1495 Longs Gap Road Carlisle,PA 17013 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for PI a int i ff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 ALL THAT CERTAIN lot of ground situate in the Township of North Middleton,County of Cumberland and Commonwealth of Pennsylvania,more particularly bounded and described,as follows,to wit: BEGINNING at a point in the eastern line of the Long's Gap Road and at the line of property,now or formerly of Sherwood Schlusser;thence in a northerly direction along the said road one hundred(100)feet to a point at the line of land,now or formerly of Harold E. Schlusser and Mabel P. Schlusser,his wife;thence in an easterly direction along land,now or formerly of the said Schlusser four hundred seventy-eight(478)feet to a point at the line of land, now or formerly of William Brownawell;thence in a diagonal direction along the fence line between property,now or formerly of the said Brownawell and the lot herein described,a distance of three hundred twenty(320)feet to a point in the line of property,now or formerly of Sherwood Schlusser;thence in a northerly direction along land,now or formerly of Sherwood Schlusser;a distance of one hundred twelve(112)feet to a point;thence in a westwardly direction along the same,a distance of three hundred(300)feet to a point in the eastern line of the Long's Gap Road, the Place of BEGINNING. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY TOWNSHIP OF NORTH MIDDLETON BEING PREMISES: 1495 Longs Gap Road, Carlisle,PA 17013 SOLD as the property of Tiffany M.Wilson and Andy F.Russell TAX PARCEL#29-05-0425-046 BEING the same premises which Nancy C. Monismith, a single woman by deed dated 5/13/2010 and recorded 5/14/2010 in Cumberland County In Deed Book instrument#201012352 granted and conveyed unto Tiffany M.Wilson and Andy F. Russell adult individuals, as joint tenants with rights of survivorship and not as tenants in common 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 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus, OH 43219 Plaintiff of Cumberland County VS. ANDY F. RUSSELL CIVIL ACTION-LAW TIFFANY M. WILSON (Mortgagor(s)and Record Owner(s)) 1495 Longs Gap Road ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 13-3418 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: 1495 Longs Gap Road Carlisle,PA 17013 1.Name and address of Owner(s)or Reputed Owner(s): ANDY F.RUSSELL ' 1495 Longs Gap Road , Carlisle,PA 17013 rT1 C-_ r TIFFANY M.WILSON'y, , 1495 Longs Gap Road Carlisle,PA 17013 a 2.Name and address of Defendant(s)in the judgment: * ANDY F.RUSSELL 1495 Longs Gap Road Carlisle,PA 17013 TIFFANY M.WILSON 1,495 Longs Gap Road Carlisle,PA 17013 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be,affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1495 Longs Gap Road Carlisle,PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: KML LAW GROUP, Michael McKeever Pa.116129 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, t� < P� 13-3418 i L L;'') KMIL Law Group,P.C. J1 ; Suite 5000-BNY Independence Center P,c t H otio 78/3 AUG 701 Market Street 4 Philadelphia,PA 19106 (215)627-1322 L!"%JL9ERL/q�D Attorney for Plaintiff P JPMORGAN CHASE BANK,NA 3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW ANDY F.RUSSELL TIFFANY M.WILSON ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 1495 Longs Gap Road Carlisle,PA 17013 Docket No. 13-3418 Defendants� 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: RUSSELL,ANDY F. ANDY F. RUSSELL 1495 Longs Gap Road Carlisle,PA 17013 Your house at 1495 Longs Gap Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$171,163.93 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 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. 13-3418 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. I. 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 7177240-6390. 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: hU://www.12hiladelphiafed.orgjforeclosure/ 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 13-3418 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.pbfa.org/ -- — consumers/bomeowners/leal.as R x. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(4jkmllawg.,roup.com.com. -825-6329 or fax 215-825- Call Seth at 215 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 121793FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-3418 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 3415 Vision Drive FTHECCOUR OF COMMON PLEAS Columbus, OH 43219 erland County Plaint iff vs. CTION-LAW ANDY F. RUSSELL TIFFANY M. WILSON ACTION OF MORTGAGE Mortgagor(s)and Record.Owner(s) FORECLOSURE 1495 Longs Gap Road Carlisle,PA 17013 Defendant(sA Docket No. 13-3418 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: WILSON,TIFFANY M. TIFFANY M. WILSON 1495 Longs Gap Road Carlisle,PA 17013 Your house at 1495 Longs Gap Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$171,163.93 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 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 judgmen t, 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. 13-3418 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale.(See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hM://www.philadelphiafed.orWforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-3418 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.pbfa.orp-/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@kmllawgroLip.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 121793FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3418 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,N.A.Plaintiff(s) From ANDY F.RUSSELL,TIFFANY M.WILSON (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 gamishee(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: $171,163.93 L.L.: $.50 Interest FROM 5/1/2013 TO DATE OF SALE PER DIEM AT$25.12 Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.53 Other Costs: Plaintiff Paid: Date: 8/6/13 J David D,Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name. SALVATORE FILIPPELLO,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,313897 KML LAW GROUP,P.C. 121793FC Suite 5000 CF: 06/13/2013 BNY Mellon Independence Center SD: 12/04/2013 701 Market Street ' ' � ' �`� ' � r' $171,163.93 Philadelphia,PA 19106-1532 215-627-1322 �,N `0: t 2 Attorne y for Plaintiff `,1,1 M R- P I r n g n,,;, . JPMORGAN CHASE BANK,NA PEN YLVAN! E COURT OF COMMON PLEAS 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff VS. CIVIL ACTION—LAW ANDY F. RUSSELL ACTION OF MORTGAGE FORECLOSURE TIFFANY M. WILSON Mortgagor(s)and Term Record Owner(s) No. 13-3418 1495 Longs Gap Road Carlisle,PA 17013 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). (X) Certified mail by KML Law Group, P.C. (Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). ( ) Certified Mail&ordinary mail by KML Law Group, P.C. (original receipt(s)for Certified Mail attached). ( ) Published in accordance with court order(copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders(if any)has been made by ordinary mail KML Law Group,P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, 1 , BY: Veronica Cosine Legal Assistant i p m <o ,ter Tw - W cad s �,¢ a N � 0 s 11NC1 0 0 0 c d E d N V m a c m 0 C O toL _ N _ a =U c�[9tTQv =N v p LL LL t C it E a� _ ��i xy�o O CO) a°o fq v c d d Z d e m Q Lo IL cc 0 c m y U c O a d U Y C N E _ Z N S.CO C U a LLJ _ � d a W °?t R E W Cl) C. N E m m y d N N ti �wwU U _U v 0 o CL DODO tL J U 0 E Y O m C w Lo (D _d W 1, O) Q c Z 0 v - N S E cr) c°i a O a- o Q m U O H �� o Cl y o W m.B E o a 0�L z a CL cc E dpi 0. n� U N0- _C rn a C U UOti� c X a U N 5 DODO❑ W Z O N W N w y d 0 1E N c t E OOO`N N Z aln❑ W J_ � N a (D!F= O C a.0 =$ } o0 U Q E a v tL z> o H d E o °� v J 16 �a M v � a L d U)Q d -6YC)WCLcN o� M LUL ¢UoYJm �,c m mmLoQp� EU) L0 p EQIW2<o Za a 04 Q z O Z)o 3:6, cri ui co ti c6 ° cr) .- 92UNITED STATES POSTAL SERVICE Date: August 29, 2013 kalilah osei: The following is in response to your August 29, 2013 request for delivery information on your Certified Mai ITM item number 9171999991703294172643. The delivery record shows that this item was delivered on August 23, 2013 at 4:30 pm in CARLISLE, PA 17013. The scanned image of the recipient information is provided below. Signature of Recipient Address of Recipient A Lc) Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service UNITED STATES POSTAL SERVICE Date: August 29, 2013 kalilah osei: The following is in response to your August 29, 2013 request for delivery information on your Certified MaiITM item number 9171999991703294172636. The delivery record shows that this item was delivered on August 23, 2013 at 4:30 pm in CARLISLE, PA 17013. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : Lon � S (vT Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service 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 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW ANDY F.RUSSELL TIFFANY M.WILSON ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) Term 1495 Longs Gap Road No. 13-3418 Carlisle,PA 17013 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: 1495 Longs Gap Road Carlisle,PA 17013 I.Name and address of Owner(s)or Reputed Owner(s): ANDY F. RUSSELL 1495 Longs Gap Road Carlisle,PA 17013 TIFFANY M. WILSON 1495 Longs Gap Road Carlisle,PA 17013 2.Name and address of Defendant(s)in the judgment: ANDY F. RUSSELL 1495 Longs Gap Road Carlisle,PA 17013 TIFFANY M. WILSON 1495 Longs Gap Road Carlisle, PA 17013 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1495 Longs Gap Road Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 12, 2013 KML Law Group, P.C. BY: Veronica Cosme Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ff } " 1 { wn� :s. +tr of a�tn tii Jody S Smith Chief Deputy 2D111 JAN 22 2: 31. .> Richard W Stewart et RLANS CITY Solicitor QF CE C THE S ERtF Yl.itANlA JPMorgan Chase Bank, N.A. Case Number vs. 2013-3418 Andy Franklin Russell (et al.) SHERIFF'S RETURN OF SERVICE 09/30/2013 03:41 PM - Deputy Brian Grzyboski, 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 1495 Longs Gap Road, North Middleton -Township, Carlisle, PA 17013, Cumberland County. 11/27/2013 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 1/8/2014 12/19/2013 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 2/5/2014 01/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $912.17 SO ANSWERS, 17( January 21, 2014 RONNK ANDERSON, SHERIFF 3e' 7'3 ,-, cul),Suite,Srer,11.Telecsoh Yr • On August 8, 2013 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 1495 Longs Gap Road, Carlisle, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 8, 2013 By: B44-1-1-1)(t-62-1-r Real Estate Coordinator :, LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-3418 Civil Term TAX PARCEL#29-05-0425-046. BEING the same premises which JPMORGAN CHASE BANK,N.A. Nancy C.Monismith,a single woman vs. by deed dated 5/13/2010 and re- ANDY FRANKLIN RUSSELL, corded 5/14/2010 in Cumberland Tiffany May Wilson County In Deed Book instrument # 201012352 granted and conveyed Atty.:Michael McKeever unto Tiffany M.Wilson and Andy F. ALL THAT CERTAIN lot of ground Russell adult individuals, as joint situate in the Township of North tenants with rights of survivorship Middleton, County of Cumberland and not as tenants in common. and Commonwealth of Pennsylva- nia, more particularly bounded and described,as follows,to wit: BEGINNING at a point in the east- ern line of the Long's Gap Road and at the line of property,now or formerly of Sherwood Schlusser; thence in a northerly direction along the said road one hundred(100)feet to a point at the line of land, now or formerly of Harold E. Schlusser and Mabel P. Schlusser, his wife; thence in an easterly direction along land,now or formerly of the said Schlusser four hundred seventy-eight(478)feet to a point at the line of land,now or for- merly of William Brownawell;thence in a diagonal direction along the fence line between property, now or formerly of the said Brownawell and the lot herein described, a distance of three hundred twenty(320)feet to a point in the line of property, now or formerly of Sherwood Schlusser; thence in a northerly direction along land, now or formerly of Sherwood Schlusser;a distance of one hundred twelve (112) feet to a point; thence in a westwardly direction along the same, a distance of three hundred (300)feet to a point in the eastern line of the Long's Gap Road,the Place of BEGINNING. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY TOWNSHIP OF NORTH MIDDLETON. BEING PREMISES: 1495 Longs Gap Road,Carlisle,PA 17013. SOLD as the property of Tiffany M. Wilson and Andy F.Russell. 100 The Patriot-News Co. 2620 Technology Pkwy C atriotXtws Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 1134448 CFr11 Morns This ad ran on the date(s)shown below: J CHASE RANK, 10/13/13 Ilitaay May • vAlson 10/20/13 Any iilewsyss 10/27/13 ALL THAT CERTAIN lot of ground situate �� in the Township of North Middleton,County of Cumberland and Commonwealth more particularly described,as follows,to*it BEGINNING at a point in the eastern line o of the Long's Ca Road and at the line of N Sworn to a d'subscribed before m: 1 •ay of November, 2013 A.D. property, now or formerly of Sherwood ^ S c h l o s s e r;tb iB,a northerlq direction edp0irl > 0 {lOOJ- / / fen to a point at-the lip of land,now or Nota Public formerly of I3arrold E.Sdslusser and Mabel P.Schlusser,his wife;thence in an easterly direction along land,now or formerly of the 1 said Sdtiusser flour hundred sevety-eight �� (47S)feet to a point at the line of land,now .° MN 3iPP EA1,Ti•i OF PENNSYLVANIA or formerly of Wi liam Brovmawell;thence t^sa:ai Seal in a diagonal direction along the fence lino 1ollV }nn�i=,sf€i,lsotary Public between pmpmty/now or fotm�y of the A!aSh nat ^;ur,,ra uPhsn County said>lrownawell and theIotheteindesaibed, My Commission Expires Dec.12,2016 a distance of enty(320) MEM*RR,PENNSYLVANIA ASSOCIATION OF NOTARIES feet to a point in the line of property,now or formerly of Sherwood Sddusser;thence in a northerly di;ection along land,•now or E......>.h,of Cho.muar Crhh,ccpr 2 distance