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Home My WebLink About13-3543 Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: j Cumberland County y /`�J ` V1 I ) S The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S F Transfer from Another Jurisdiction [] Declaration of Taking E Lead Plaintiff s Name: JPMorgan Chase Bank, Lead Defendant's Name: Joel Nye; Debra Nye National Association successor by merger to Chase C Home Finance LLC successor by merger to Chase T Manhattan Mortgage Corporation I Dollar Amount Requested: El within arbitration limits p Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ Check here if you have no attorney (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 APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander/Libef/Defamation ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: , E] Other: I El Other: O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/1011 M SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation NO: < l � / PLAINTIFF J 1 t 1 VS. 1 - Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 ' Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 1 " DEFENDANTS -< e COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE 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 THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. f Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 - 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Y NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 k SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation �� n �� • PLAINTIFF NO: VS. Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation, the address of which is, 3415 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee The Washington Savings Bank, FSB Mortgagor(s) Joel Nye & Debra Nye (b) Date of Mortgage June 30, 2003 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Mortgage Book 1834, Page 4001 Date: September 9, 2003 f' r The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: The Washington Savings Bank, FSB Assignee: Chase Manhattan Mortgage Corporation Date of Assignment: July 18, 2003 Recording Date: July 9, 2004 Book: 709 Page: 3725 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property which is subject to the Mortgage is generally known as 6056 Edward Drive, Mechanicsburg, PA 17055 and is more specifically described as attached as part of Exhibit "A ". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as Exhibit "B ". 5. The names and mailing addresses of the Defendants are: Joel Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 and Debra Nye, 6056 Edward Drive, Mechanicsburg, PA 17055. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2012 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of May 13, 2013: Principal Balance Due $122,448.28 Interest Currently Due and Owing at 5.25% $5,357.10 From July 1, 2012 through April 30, 2013 Late Charges $126.00 Escrow Advances $853.66 Property Inspection $28.00 TOTAL $128,813.04 9. Interest will continue to accrue each day that the debt remains unpaid, subject to further adjustment as set forth in the underlying Mortgage and Note, and Plaintiff may incur .other expenses, costs and charges collectible under the Note and Mortgage. 10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ". 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: l lb� BY: Attorn s for aintif S & D File No. 13- 043262 A r 57) RLANa 08UNTY '� AND S 'M ce mac, eras '03 SAP 9 Aft 1120 420I M ICHiCI.Y.V= -X ROAD, t3i7[Tl3 300 Bowie, MDmn6 � v [Spam Ab TNd L&m For Rbe-ft IMtq Co o, o P "mylvanla MORTGAGE Pm Cm NO. 150 ID if THIS MORTGAGE ( *Security Instrument") is given on June 30th, 2003 The Mortgagor is foal Nye a:ud bakwa my" ( "Borrower'): This security Inhumed is given to The Washington savings Sank, F98 which is organized and Wetigg under. the laws of TIM UXZTSn MMTHS 07. lltd XCA , and whose address is 4101 Kitebal.lville Road, Sto. 300, Sovis, Hasylend 307L6 ( "Lender') Bonower owes Lender the principal am of -Ox7&. Ruafted. Forty. Five : - Thousand Bight Randred and no /100- - - - - - -- _'Chic debt is e9ldenced by Borrower's note dated tho same date. as Ws Security 'Instrume nt ("Note, whioh.;prnvides for mouNy payments; with the:frill debt, if not paid earlier, due and payable on . ' July ist, 3033.. . 'phis Security ]nst<iiweSt sec 0011 to Lender:, (a) ft repayment of the.debt.evidenoed by the Note, with intCresi; 'and all renewals, WdeASions.and modiiCadona of the Note; (b) the Payment of all other I sums, with interest, advanced under paragraph 7 to promo the security of Bits Seeadty matt uneiit; and (q). the performance of Borrower's covenants and agreements Under Ibis Security Instrument and the Note. For thee purpose, BarroWer does heresy ufortgage, grant and oonvey to the Lender the following desmdbed property Iocated in Vumbetland* County, Pennsylvania: Bee attaahod vxhibit RAW m 4196 OWN PAPMlG'F - 022$AOx Peas l of -e www.�o awp Ut1 834PG400 Loan ID 4 which. has the address :of Sass adw&rd Drive, l schmicsburg , ll [i 1 PenWlvania 2.7 0.55 ("Property Adtiress"); (ZIP CO&I TOM3TH13R WrM all the improvements. now- or hereafter erected on the property, and all casements, and fixtures �w or a part of the property. All replacements and ad4doW mall also be covered by this Security 108ttument. At of the forogow' ' 2.a. refezred to is this.security 10tromtmt as the "Property." BORROVM CO 1t,NTS tttat Borrower is lawfully seized of the estato hereby conveyed and has the right to no p, graut and .convey ft 'Prop" aiui. that. ft a Property is uneneumba4 . Mwe for � of record. Borrower warrants and.will defend generally the title to the Property against all claims and demands, subject to any encaunsbntncss ofrecord. TMS SBCURITY INSCItUMBNT combines uniform. covenants for nattojul use and non - uniform oovenents with limited vadations by jurisdiction to oonadtute a:uniform security instrument covering real property. Borrower and LAn46r covenant and agree as follows: UNWORM C)O VE ANTS. 1. Payment 'ot rJ*djW, Iataresi and We Charge. Borrower shall pay when due the principal of, and interest on, flea debt ovidenced.by ft Note and:late.eharges dun under rho Note. - . 2. Nolk* Payrnarct of Taber, itnstn' cv and Other. CUrges. Borrower shall include in each monthly payment, togedter with the prindpal and interest as set ferret it the Note and-any late dbarges, a sum for (a) taxes and special assessments Wed or to be levied against the Property, (b) leasehold payments or groin rents on the Property and (c) premhutng for inecirance regarred' under paragraph 4. Iii any year in which the Lender must pay a mortgage irtsWUM premium m the Secretary of Housing and Urban Development ( "Secretary'), or in any year in. which suds pseenima would have been squired if L.e ader still paid the Secadty Instrttn+ent; each monthly payment shall also Wu& either:. 0) A guin: -for the - ionval mortgage: iitsttfauca premium to be paid by Lender to the. Sec rctaty, or "a monthly Charge instead of a i W;11(gage Ingurrinae .prietdum if ibis Security Instroitrent is hdd: by the Secretary, in a reasonable amount to be deteradned by the Secretory :. wept for the imonthly china by the Secretary, these items are called "Escrow Jew." and the -sews paid ld Undtr.ana dulled "Escrow` Punds." - Leader may, at. iny tit4e, collect and hold'am ous for: Hscroaw Item in in aggregate amount not to exceed fete maxhman amount that maY' °ba fCO4ri fo tortdwtr's escrow aeraonnt.mWer the heal Estate .Settlement Pmoedures Act of 1974; . Y2 U.S. C4. Section 2601 et .set. grad impl6nonting regulations; .34 CM Part 3500, as, they may be amended 'from time to time ("RI3SPA '), except A* the edshion or reserve permitted by RESPA for unanticipated disburs=nu or disbursements before the llorxower's are available' in eke acaoubt may not be based on mabunts due for the mortgage inatlfanre ptenaittm. If the amounts held by Lander for Escrow hems exceed the amounts pmm tfed be held by RESPA, Lewder shall account to Borrower for the exocss finds as required by RESPA, If the aswumts of funds held by L.endcr at any time' are not sudliaient to pay the Escrow Items when due, Leader may notify the Borrower and regatire Borrower to maloe up the shortage as permitted-by RESPA. The Exrow Fonds are pledged as additional security fbr all stems sbcttted by this Soarrity Wstrament. If Borrower tenders to .,reader the duet pa*W-'of ate Borrower's account shall be credited with the balance nemainiq for alt installment ittut� (a), ibj, t f (c) and any .ittottgage'innamwe premium installment that L;encltur has rot become obligated`to pay to t]tis 5eci ; : and I Cgdek shall promptly refund an;v tirctss fupds to Borrower. Irnmodiately prior to a foreclesu i saI6.of ltte Property or its abgrCisidoa by I.cndtr, Horruwer's 'account ahaU be =W with any baiance smarm I* for all 6fa11ments for it= (a); (b), and (c). TNMI initials: PAFM O.. e1 MM Pace 2 of 8 �►ww.Pri � 0 :1834P64-n Loun ID f1 3.. Appddc;ation "of Pgmm* All payments raider paragraphs 1 and 2 tit U be applied by Lender as follows; Phut; -to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary . instead. of . ft monthly mortgage inaarArure pcemiUmt . ,, to any takes,. special ate, kasehold payments or ground rents, and fire, flood and other hazard • imct[amcb premiums, MkI to interest due under the Note; airk to amortization of the pri ndpal of -dW Note; and , to Iata charges due under the Noce. .4. Ilr+e, Flood and Other Board Ymaorruaca. Borrower shall hmn. an irngrmvpnob on the Property, whether now in miatemcu or edbsequody created, against any hazards, cmalties, and condAgencles, including fire, for which - Lerrder requires b suranod. This inswanae shall be maintained in the amouats.and for the pmiods that Lender requires. Borrower shall also insure all improvements on tine Property, whetirer_naw in a dewe or sobsegvently erected, against loss. by floods to ft cxW required by the Szcrehry. All insurance sball be carried with companies approved by Lender. The irmiiance polities and any renewals. "be heM by Lender mad shall include loss -pay" clam in favor of, and in a form acceptable to, - Lender. - in; the event of loss, Borrower shall .give Lender immodiaw notice -by mail. Lender may make proof of loss if not made prouptly by .Borrower.. Each insurance company co=rned is hereby mAoriaed and directed to make paymat . for such loss directly to Lender, instead of to Borrower and to Lender jointly.. All or any part of the imsuraaee proceeds may be applied by Leiadtx, at its option, tidier (a) to tilt reduction of the i'ndebtedmess under the .Note and this Seemity irestru meat, first to airy delinquent ataounts applied in the order in paragraph 3, and then to prepayment of prin dtpal, or (b) to the restoration or rejWr of the damaged Property. Any applioatioir.of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referrod to im paragraph 2, or change the amount of each payments. Any excim insurance pwcoeds: over an amount nogaired to pay all outstanding indd*d=m under the Note and this Security haft went shall be paid to the entity legally entitled thet'eto. in the event of fofoclosdre of this Security .lnetram ent. or other transfer of title to the; property that excingniAes the indebtedness, all right. titio `and i i of Borrower in surd to insnrsoft: pDWcs in force shall pass. to the purchaser. Ompancy,_ .Pt vmmtiot, Maintenaritx and Pebtection of the rroperty; bo rrowlr's. Loma Appitcmtlonl Leameholds. • .Boazowar abdi occupy. 'establish, anti..use die. Property as Borrower's principal residence within sixty days after the execvdon of this 5ecari_ty Intl (or vd(hin.sixty days of it later alto or transfer of the Property) and Sian continue to oocUpy sac Property 88 residence residue for at least one year after the date of occupancy, unless Leader determincs drat roqudtomept'JViII cause =dw hardship for Borrower or unless extenuathtg circwwtances exist.whiah are beyond Borrower's control.: Borrower shall notify Leader of any extannatiag rcamstanc es. Borrower shall net commit waste or destroy,, dmmge, or mfttant[Ally change the Property or:allow the Property to deteriorate, r�easonabl - wrap' and. tear. excepted. Lender may itapeot the Property if the Property is vacant or abandoned or the loan is iu dof alt. Lender may 'tfibe easormble action to .protect and preserve such vacant or abandoned Pro" Borrower sbadl "be in dtf uh if Boxrawer, dddng the 'lima application procotis, gave uaberiatty false or inac owa'te information or stmemients to Lender (oi tailed to Pro" LMXkr'.*With aqy: material information? is com =don with the loan evidenced by the Note, including, but rot it olte d to, represenat fiM concerning Borrower's occvpaney. of the Property as a principal rssidence. If tads Security:lmauumemt is on a leasehold. Borrower shall comapiy with the provisions of the lease. if Borrower acquires fee title to the Ptroperty, the leasehold and fee title shall not be merged unless I ender agrees to tin merger in writing.. 6... Conde don. IU proceeds of any award or claim for damages, direct or consoqueatial, In connection with any cookuma ion or :q* taking of my part; of the property, or for 10nvcyauce ire place of condeeamadoa, are hereby assig d.. * v d sli ll : be paid•to.I.ender to the s xtcnt`of the full amount of the indebtodrtes6 that M na%ns Unpaid uo* the Note and this .Security lj�sbumenL Lwrdpr shall apply such proceeds to the roducdon of the indebtedness ender the Note and this Security Ynsti�ettt. Srnt to any delinquent amounts applied in the order provided in paragraph 3, and then to - Iantials: PANSOG : Ot7.ttt802 Pace J �f a wwrr, mar ON] - 0.34 reran. ID ei *- prepayment of principal.. Any application of the prooteds to the principal shall not extend or ppstpono the due date of the torouddy Payments, which am refet'rtd to in paragraph :2, or change the amount of such paymmts. Arty excess proceeds over an ttnaunt requited to pay all outstanding indebtedness utulsr the Note and Us'Security :Instrument etiall be paid to the en iO 144' ~ iWded thereto, 7. Cimrtett to 8oiwwer and 11nnection of- f.endwls Rights in tine Propea'ty. Borrower shag pay all govesam6tal• or municipal charges, fiines and.iimpositions that are not included in paragraph 2. borrower 'sball pay (hen obligations on time directly to the entity which is owed the payment. If failure to pay would ativexmely affect Lender's hang in the Property, upon Lender's request Borrower shall promptly furnish to Lender =04ms evideneW these PAY. If Borrower ia to make these paynotnta or the payments required by pares Vh 2, or fails to perform any other covenants and agrooments.contained in:thus Secudty hwntmebtt, or there is a legal proceeding that may significantly afiftot Leader's rights in the Property • (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), thm Lender away do and pay whatever is neoessary to protect the value of the Property and Ltv*r`s rights In the Propa q, including payment of twits, hazard ftwr�anee and other items mentioned in paragraph 2. Andy amounts disburnd by Lender under this paragraph shall become an additonai debt of Borrower and be secured by this Security Iastrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Leader, shall be inmediatelydue and payable. Borrower sbali promptly dWhatIc any lien which has priority over this Sorority Instrument unless Borrower: (a) agrees io writing to the payment OfAx -ObOVftoft.S6MnW by the lieu in a manmex aoeeptabit to Lender, (b) contests in good fail the Hen by, of d Wads againstenforbemant of the Hen ►n; legal prooeediags which in the Landcr's opinion operate to prevent the eohroemest of the lien; or (c) swum from the holder of the lien an agreement satisfactory to Lender subordiuoaft the lien to this Security Instrument, If Leader drftmines that any part of the Property is subject to a lien which tray. attain priority over this.-Security Instrument, Leader Way give Borrower a notice ldendWng the lien. Borrower snail sat4sfy the Hen or tab one or more of •the actions ad' forth above within 10 days of the giving.of notice. S. - Fem iAader collect fees .and cha>;geea aatborized by the Se o"tary. 9. Gewtutds t Acederatiote of Delia. (tt) Aitlitdait. ; l:ea>dct mq..:ePC.as limited by resgttlatians issttcd: by ft Secretary, in the came: of payment e3ciaitlts; tet(tti ci iipcnte9iaEc Par . full:of all.teums s icareti.by tills Security lastrumapt if: (i) Borrower defaults by foiling to pay in 'any y. P$y� required th by is Security lnstrament prior to or on the due date of the rjczE mamthly payracnt, or (ii) Borrower dofaolts by failing, for a period of thirty days. to pan b m any otter obligations contained in this Security Instrument. (b) sale Wttbout Credit Approval.: Lauder shall, if permitted by applicable law (including Section 341(4) of .the Chatm-.SL rnmaim Depository Institutions Act.of,1982; 12 U.S.C. 1701} 3(d)) and wits the approval of the se>cretacy, regihire ih,imoeduathr .payment m full of atI sums secvrW by this Security .instrument i$ 0) All or.pait tiP die, zopelty, or:a baflefldsl interest in •a trust evening all' or part -of the Property; is sold or odwrtvise ttsuafttred (other than by devise or descent),'and (if) The ` Property is not occupied by 0* orrebseer or pawet as his or bea . principal reside oce, or the putcfhxW r orrgrantm does so occupy the Property but Ida or hex credit has not best approved in accordance with the requirements of ttt aefttary. . (e) No WAvew. If citcuiist mccs •occur that would permit Lender to require Immediate payment in fall, but . I.enodex does - not .>b qu. saoti payments, Lida not t waive Us rgghU with. respect to sabsogtte ut events. (en Re nlati iihic of iiiicm SeC1Vb y.:. A many ciMu=tanoe:s regrrlatiM issued by the Secretary wiu limit :Lender's g>irs,,.in the :ewe of payment defaults, th. z+�irr -Immediate payment in full sad foreclose if not paid. This Sedulity, Iattinmem does :not au a= Caw)an or fonoelosurc If.not periAtted by mgalatioas of the .Secretary. . Initials: PAhM4G . OZLS. M Pane 4 of a +oNtr btu 8K :)".844 PG 4 4 4 4 Loan 3M if (e) Mortpp Not b un& Borrower agrees drat if this Security Instrument mmd ft Note are not cletenmiaed to be eligible for insurance under. the National Housing Act within 60 days from the. date hereof Lender may, at .its option jm fail o soma secured by this Secnricy Instrument. A written statement of any audnori:cad agent of ft Secretary dated subsequent to 60 days from the date bwoof, declining to insane this Security lastrumment and-the Note, shall be deemed conchusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by. Leader when the unavailability of insurance is solely due to Lender's Failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if bender has replied Immediate payment in full because of Borrower's failure to.pay an amount due under.the Note or this Security Ynatrn ncm This right applies even after foreclos"ie..proceodioga are instituted, To Mnstate the Security Instrument, Borrower sWel1 tender in a WW stun ail arrmunts m. bring'lRorrowor-1 account t , fo the Ocxtentthey are obligations of Borrower under rmcjudreet @ds Sextiuir#ty Iffihnmdaat, fnr+cclosare costs•a. S easomble.and customary attorrsays' Esau and expenses properly associated wthe ith foi6clomire prowm . ag.. Upon reinstdblunt by Borrower, .this Security Instrument and the obligations that it swam shall remain in effect as if Lander had not required immediate payment in full. However, Lender is not mq*".to permit reinstattlneat if. (i) Lender has accepted rdnsiatmeat alter rho coxmamoncement of foreclosure proceedings wltldn two years immediately preceding the eonmmenceraont of a canent 6oreclosuro preweding. (1i) rent win preclade. foreclosure on different grounds in the txrture, or (111) reinstatement will adversely affect the priority of the Ilenn created by this . Stxurity Ins u. M Borrower Not.kdesv* Forbearnce ft. Lendei Not o Waiver. Bktensiort of the time of payment or modification of amortization of the sums seWred by this Security Instrument granted by Lender to any sueoessor in interest of Borrower shall not operates to rcl m ills liability of the original Borrower -or Borrower's successor in interest. Lender shall not be raquirod to commence Vmccedinge• against any successor in interest or rouse to extend time for payment or otherwise modify amsortiration.of •the sums secured by this Secs rity "txaravat by rceson of any demand made by the'OO& l Aormwer or Boriower's mwoessors in intermst. Any forbeamuce. by Lender. in exercising any right or r+en iefy sbau riot dirt a a►giver -of :or - preclUkle: the exercise of any right ox .remedy. 12.. t ors road :Assigns Bontiuds :Joint anti Screwed Litibllity; Co- Mgnews. The covenants and agreements of this Security Inetruiment ufiaU birld and. bcmefit ire successors and assigns an of1a.d r d Borrower, subject to the provisions of. puagmph 9(b):. Borrower's covenants and agreements .shall be joint and several. Any Borrower who co- signs this Security insomment but does not execute We Note: (a) is c:o -ShOM this ScGM* Instrument only to rmrtaage, grant and• convey that,Borrewer's interest in the Property under the terms of this Security inaturmul. (b) is not personally obligated to pap the sums secured by this Security anstruioment; and (c) agrees that Leader and any other Borrower may agree to. extend, modify; forbear or maim Any accommodatlons with regard to the terms of this Security Instrument or•tlte Note witlmat that Borrower's o6asent. 13. Notices. Any hotico to Ron . owe:r provided for in this Security Instrument shall be given by delivering it or by mailing itt by first cliass =41 oarless. gT1I ablalaw :.rex irce' :use of and method, The.aotice shall be.directed to the Property or. any other:address .8ox:owcr .designates by notice to Lender. Any notice to Lender shall be given by first class mail to, I. end errIs addwss stated herein or any address Leader desrgnetes notice to Borrower. Any notice providedfbor in this &=* Instrument sWtTt be deemed to have been given to Soirowen or Leander when Given as provided in this paragraph. 14. Gowning Law; Se exability. This &cu rlty Instrument shall be governed by Federal law and the dew of the )LmiA — ctiou is wMch the -ftd Y.y is located: In tiro event that any provision or clause of this Security Iusmument or the Note conflicts NUM VP law, slush. ca nflit;t &Frail not affect o*a of this'Scumity In mmut or the Not which. oar be given effect withelhrt fire conflicdng provision.. To this emd:tho pmvisioas of diis.s=riny lnm m mt.and_the Note are docUmd.t�o be.sevcrable... IS. laormneg C". .Borrower "be given are confomQed copy.of the Note and of this Security instrument. Initials: FAt3MA - O M2M Par 3 or a WW K,134PG4OD5 Loan SD tt 16: Hazardous - Subffuum s. Borrower shall not caries or permit the presence, use, disposal, storage, or reloasc.of any Hawzdm Substances at or in the Property. Borrower shall not do, nor allow anyone else to 'do, anything affecting the Property &at is is violation of arty Eavitoamentel Law. The pte�ing two sentences shall not apply to the px since. use, or storage on the Property of Mmll quantities of Hazardous SaUtances that are seanerally recognized to be appropriate to normal residential uses and to malownw= of the Pro", Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazatrdous Substance or Em4ronmerntal Law of which Borrower bas.actoal knowledge. If Borrower learns, or is notified by any govemmental or regulatory authority, that any removal .or other remediation of any Hazardous Substaxices afl'oe ling rho Property is necessary, Borrower. Shall ,promptly take all necessary remedial actions In accordance with Environmental Law. As used in tbis paragraph 1.6, "Hazaidtius Substances" are those substances defined as toxic_ or hazardous substances -by Buoironmental Law. tits: following subsIspoes: gasoline, locnos=, other flammable or toxic petroleum products, to* pesticides and herbicides volatile solvents,, materials conta� asbestos or formaldehyde, and radioactive materials. As mood In ibis �b:16,. "Bnv6nimental Law" means Weral laves and laws of the jtntisdiction where that the Property is located .relate to. health, safety or environmental protection. NON- UNWORM COVENANTS. Borrower aml I farther covenant'and agree as follows: 17: Assigurne t .of Rents. Borrower'unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower auf crime Lender or Lender's agents to collect the - rents and revenues and hereby directs each tenant of the Property to pay the: rents to l uxadexr or, Loader's ' agents. However, prior to Lender's notice to Borrower of 8orrowees hgoaa of.any covenant or agreemert in the Security Instrument, Borrower shall collect and receive all routs and revenues of. the Property as trw tic for the bgdefit of Lender and Borrower. This assignment of rents continues an absolute assignment and not as assignment fAr nal'aaarrity only. ' ' . Lcxk r gives; notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as ttuslee far benefit I.endar only, to be applied to the sums secured by the Security Iastrtrment; (b) Lender shalt be entitled to collect and receive all of the rents of dte Property; and (c). each truant of me Praporty shalt pay all rents due and unpaid to Lender or .Lender's agent on Lender's written demand to the WM L Borrower has exocin W any prior assignrocnt of the rents.and has.not turd will not perform any act that would prevent.Lender f'rum exeioisiog.its rights underthis.pmgrg& 17, Lender shall not. be ragged tq entcr:.upon,..tdv control of.-or m�aiotah the Property before or afar giving notice of breach to Borrower. '. However; lAnder or a juliliC' iy ap ioia receiver may do so at any tines tb= is a breach. Any application of iww.shall rot cure-or . walve any default or invalidate any,• otber right or romcdy of Leader. This assignrient of rents of the Property shall =mince when the debt secured by the Security Insaument is paid in fu11. 1$. Fbr'eclo=m Prooedwe.. ilt Lender requires lmmnediate paynmt in fall under paragraph 9, Leader may for edLm:this Setxia4y wftwea byjudleial proceeding. Lender slaaA be ermtitied to collect oil rupees Incurred in patrsttbrg the ftimAw provided in this ptiragmpk 19, Including, but not limited to, attornttye rear and costa of t<tk.anvldaurcx. .. . U the Lender's is interest to .tlils 86ca ty lath anent is hold by eke Seer Uu7 mad tine Sewdtary mires lnrmed me payawAi in Wonder paragraph 9, flu Sece'etary may ia►volae the aoqjudldal power of ale provided in the''Stooe Bandy Mortgage Forodosum Acct of 1994 ("Act") (12 >s &C.1'f51 er seq.) by requesting a foreclosure comalsstoner dedpmtited under the Ad to.commence foreclosure and to all the Property as provided in the Act. Nothlug In the p,eceding;sattence shall deprive fire Secretary of any rights otherwise available to a. Leader under tlifa . praerapb - 113 _ do applicable law.. .:19: Ramie: Up'ou,payment, of all anima secured by Security Instrument, this Security Irisnnrment and the estate conveyed t� . shall 6siio - red bet anre void Alter such 6ccurreace, Lcndcr ,hail dimbarge and satisfy this Security Laxstrumerrt vvitdXmt.zharge to Borrower, itomawer.:shall pay any recordation" sc oene lnitiais: PAIfi1t9Gt - a2292o0�V Ihipe b ni b www son �f:1834P r . Loan YD *. 20. Walvers. Borrower, to the extent permitted by applicable law, waives and releases atay error or defects in proceedings to enfoirm this. Secgrtty Insaur aeat,. and hereby waives the benefit of &uy present of future lays providing for stay of wrcc4don, extension of timme, cxrmption ftom attachment, Im7 and sale, .end homestead exemptian. 21. Rdustata ebt NAG& Bolrower'g time to. Whuitate provided in paragraph 10 d aII ext od to one lxour prior to The commenceme i Of biddWS'at a'shexiWs sale or odter sale ptuvn* to dris'Security lbsutount. 22, Ptrrchaee Money Mortgage. If any of the debt mcmed by this Security Instruft t.is tent to Borrower to acquinc title to the Property,, fts So=* lttsfruont shall be a pnrrhase money mortgage. . 13. Intact. Rate After Jud t. Bor owesr' agrees that the interest. rate payable &flea a jWpi xt is entered on the Note or in an action of- mortgage fo'mlosure shall be the rate payable from time to tiure under the Note. 24, Riders tc this SE�r* If ores o"'More ri&n are executed by Borrower and recorded together with.this Sexauity Iustrirtaent; the covenants of amt such alder shall be inooq rated into aiod shall amend and supplement the covenants and agre mew of this Swurity: Instroment as if the dder(s) were a pot of this Swurity lnitrumem [Check applicable box(es)] ❑ Condoldnium itidet ❑ Growing Equity Rider ❑ Odw [Specify) ❑ PlannM Unit Developnont Rider ❑ Citadoakd Payment Rider. BY SIGNING BHWW, Bonower accosts aid agrees to the torms contaltod In this Security Inwrvment and in any rider(s) exezmted' :by Barrowar 'a reco' tded with it. Witaftw: Jae a Borrower {Seal) D a Eye Borrower Borrower (Seat) Borrower - Borrower - Borrower PAS NM OtZMM A+ge 7 of E wxw can #fit US34K40. 7 Loam ID I Certificate of Reddeniee I, , do hereby omtify that the eacra:t address• of the wwli- nauod. Lander is 4901 "Mitchellville Road, Ste. 300, NOW1e, Ka yla" 20716 Witacm.my band this 30th day of Juae, . 9003 , -Agent of Lender CO11ttMON AY.'I'H OF l?'ENNSYI.YANGl, c m on this, Mh day of June, 200 btfora me, the uodmigned officer, personally appeared Joei xyo and Debra M►a known to too (or Uddadorlly proven) to -be the persons) wlmEt name(a) are aubsetibed to Me within inattlunmA and actor_ owledged that =Y — Cxw%W the ramie for.tbe.paiposes hmvcm contained. IN WITIVM Wi1BIWOP, I bareiduto set my hand and offieW seal. My Commiss ion g[pl I NCTAFML SEAL JA# 93 A. MILLEA, Notary PWIC bwo of Camp ilMl, Cumberland County, PA My Catnmhdoo`&Wr- Apm 90.2005 Title of O f C01 this to be recorded fn C'umbcrland County PA S Mf. Recorder of Deed PAPMG • 02252002 J, p�Pme t st 8 p � mew"t-L RK 1:834PG4.008 Schedule C— Land Description Number IA- 2003337 -C bLL TK7lT C$R - rilu lot or piece of land eltuara in the Township of Hampden, County of Cumberland and state of Pennsylvania, hors Particularly bounded and described as lollows to wits $BOiN1IIlPG.Bt A point on th point' in at the dYvlsi e 9outrie aide of Edward Drive which an line of iota Nos. 167 and ' 159 on said at b►lani: thence 5autSouth aS dtgreea 14 .Ainute$ East along aramentiotled Edward ariva a: distance of seventy_five to a point at a point it the division line (7b) feat 157 On said bias: thence south of T.oke_Hos. .156 and 34 degrees 46 ftinutes west along Said division line a distance hundredth$ of ane hundred nineteen and eighty (114.8G) teat to a point at land now or late of Kenneth Y+ant91 *44ioe North s4 degrees 20 minutes West along the iforikMentioned 1,n of Lantz aev"ty -five and one hundradth (75.01,) rest to a point at the fins of Lots 4 i57. and 15 thence North 34 de tees.46 minutes FAst ._alang:sNOa. and is -a distance of one hundred 61- ghteen arW is hundredths line (x18.8]) feat to a point the PLRCB of BEGINNING. In Pla nts Lot No. 151 on Plan of Nall Acre$ which plan is recorded In Plan Book 1o, page 17 Cumberland County re Gorda. WIV%Nd.thareon erected a single family dwelling known and numbered as 6066 Edward (Drive. . r BK. 1- 34PG4009 Loan ID 9 Multistate N NOTE June 30th, 2003 Camp Hill, Pennsylvania [Date] [City] [swel 6056 Edward Drive, Mechanicsburg,- PENNSYLVANIA 17055 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means The Washington Savings Bank, FSB and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of One Hundred Forty Five Thousand Eight Hundred- - - - - - - - - - - - - - - - - - - -- Dollars (U.S. $ 145,800. ' 00 ) plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursemnt of the loan proceeds by Lender, at the rate of Five and one cluarter percent ( 5.250 q) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on August 1st, 2003 Any principal and interest remaining on the fast day of July, 2033 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 4201 Mitchellville Road, Ste. 300, Bowie, Maryland 20716 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 805.12 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for Payment Adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable -box] ❑ Graduated Payment Allonge ❑ Other [specify] ❑ Growing Equity Allonge 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note by the end of Fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the . Initial FHA Multistate Rate Note -12/95 AAFNSG- 09142001 Page Iof2 vvw%yMortgagaonVngSystems.com 1 , F !�; 6 i e - jl : 6 r Loan ID i event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent'not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. 'Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person if fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. _— (Seal) Joe a -Borrower (Seal) Deb a Nye Borrower (Seal) Borrower (Seal) Borrower (Seal) - Borrower (Seal) - Borrower PAY TO THE ORDER Of Chase Manharr u— X ortgage Corp. Pay to the Order of &am;! WITHOUT REGO SE NK, FSBion THE WAS SAVIN BY: Lory Ebron, sistant Vice President AAFMG - 0914200/ Page 2 of 2 www> IortgogeBnntmgSystems.rom SeheduleG- Land Description Number TA -2003 -337 -C ALL THAT CERTAIN lot or piece of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Edward Drive which point is at the division line of Lots Nos. 157 and '158 on said plan; thence South 55 degrees 14 minutes East along aforementioned Edward Drive a distance of seventy -five (75) feet to a point at a point at the division line of Lots Nos. 156 and 157 on said plan; thence South 34 degrees 46 minutes West along said division line a distance of one Hundred nineteen and eighty hundredths (119.80) feet to a point at land now or late of Kenneth Lantz; thence North 54 degrees 20 minutes West along the ' lands of Lantz seventy -five and one hundredths (75.01) feet to a point at the line of Lots Nos. 157 and 158'; thence North 34 degrees 46 minutes East along said division line a distance of one hundred eighteen and sixty -two hundredths (118.62) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 157 on Plan of Noll Acres which plan is recorded in Plan Book 10, page 17 Cumberland County records. ' I[AvING thereon erected a single family dwelling known and numbered as 6056 Edward Drive. 1 t Chase (FL5 -7734) CHASE ! i P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 1982 8877 March 13, 2013 IIIIIIIIIIIIIIIIIIIIIIIIII 00009334 HDLO CB 7213 -BR840 DEBRA NYE 6056 EDWARD DR MECHANICSBURG, PA 17050 Acceleration Warning (Notice of Intent to Foreclose) Account; 1(the "Load') Property Address: 6056 EDWARD DR MECHANICSBURG, PA 17055 (the "Property") Dear DEBRA NYE: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A. ( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due August 1, 2012. 2. As of March 13, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $8,428.40 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848 -9380. Total Monthly Payments $8,372.40 Late Fees $42.00 NSF Fees $0.00 Other Fees* $0.00 Advances* $14.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of April 15, 2013 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. Ex h 1 / G If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before April 15, 2013, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. 8. Kindly remit the total amount due, shown in.Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848 -9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You 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. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at (800) 569 -4287 or at www.hud.gov. Sincerely, Chase (800) 848 -9380 (800) 582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling 888 - 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR840 An important message from the Federal Trade Commission note to Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell -tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise. Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free. but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly. This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD - certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion. free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission ' ftc.gov/MoneyMatters Call 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD - certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov XXX HOPENOW Supp Guidance:For Homeowners / ■ v/ ■ " L SM MAKING HOME AFFORDABLE.GOV Chase (FL5 -7734) CHASE Oh l P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 1982 8884 March 13, 2013 IIIIIIIIIIIIIIIIIIIIIIIIII 00009335 HDLO CB 7213 -BR840 JOEL NYE 6056 EDWARD DR MECHANICSBURG, PA 17050 Acceleration Warning (Notice of Intent to Foreclose) Account. "Loan ") Property Address: 6056 EDWARD DR MECHANICSBURG, PA 17055 (the "Property") Dear JOEL NYE: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument') securing your Loan, JPMorgan Chase Bank, N.A. ( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due August 1, 2012. 2. As of March 13, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $8,428.40 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848 -9380. Total Monthly Payments $8,372.40 Late Fees $42.00 NSF Fees $0.00 Other Fees* $0.00 Advances* $14.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of April 15, 2013 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before April 15, 2013, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure /attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848 -9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You 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. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at (800) 569 -4287 or at www.hud.gov. Sincerely, Chase (800) 848 -9380 (800) 582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866 - 840 -5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling 888 - 995 -HOPE; 888 - 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. 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. BR840 An important message from the Federal Trade Commission A note to ;. 1Y� H Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell-tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so- called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD - certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission l `' ftc.gov/MoneyMatters 1 � r Call 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD - certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov nNA HOPENOW Support & Guidancefor Homeowners /MVM_V0 SM MAKING HOME AFFORDABLE.GOV Pennsylvania Verification STEFAN HEARST , hereby states that6iee she 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: 06/05/13 JPMor2an Chase Bank, N.A Borrower: JOEL NYE and DEBRA NYE Property Address: 6056 EDWARD DRIVE, MECHANICSBURG, PA 17955 County: CUMBERLAND Last Four of Loan Number: 5178 i FORM 1 : IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association : CUMBERLAND COUNTY, successor by merger to Chase Home Finance LLC PENNSYLVANIA successor by merger to Chase Manhattan Mortgage Corporation Plaintiff(s) VS. r Joel Nye `ZJ ' 6056 Edward Drive ... C - 1 Mechanicsburg, PA 17055 c- nI Debra Nye 6056 Edward Drive f f •• Mechanicsburg, PA 17055 DEFENDANTS Defendants Civil 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: SHAPIRO & DeNARDO, LLC Date ' A eys for Pla' iff FORM 2 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: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C O-BOR R O WER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FIN ANCIAL •' • First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes ❑ No ❑ Wo If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: 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): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Ex enses: Please only include ex enses you are currently a in EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. Payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day /Child Care /Tuft. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ 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 (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating m financial situation for possible mortgage options. I /We understand that I /We 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: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 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) FORM 3 : IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation Plaintiff(s) VS. Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 DEFENDANTS Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Defendant(s) Civil CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT J. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Defendant(s) Civil 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: IM � om — v ,- Date [Sign re o oun 1 for Plaintiff) 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: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C O-BOR R O WER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FIN ANCIAL •' • First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: 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: Monthlv Ex enses: Please onlv include ex enses you are currently a in EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2 Mortgage Utilities Car Payments Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. Payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ 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 (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating m financial situation for possible mortgage options. I /We understand that I /We 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: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 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 Sheriff THE PRO THONO-11"Ak'I Jody S Smith Chief Deputy T�4�1 2^13 JUL 18 AM 9: 59 Richard W Stewart Solicitor OFFICE OF T�15 V.9pirp GUMBERLAND COUN*I-y PENNSYLVANIA JP Morgan Chase Bank, NA VS. Case Number Joel Nye(et al.) 1— 2013-3543 SHERIFF'S RETURN OF SERVICE 07/09/2013 09:02 PM-Deputy Amanda Cobaugh, 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: Joel Nye at 6056 Edward Drive, Hampden Twp., Mechanicsburg, PA 17055. , (Amn AMANDA COBAUGH, DEPUTY�j 07/09/2013 09:02 PM - Deputy Amanda Cobaugh, 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 Joel Nye, husband of defendant,who accepted as "Adult Person in Charge"for Debra Nye at 6056 Edward Drive, Hampden Twp., Mechanicsburg, PA 17055. c Afflando, -NbnajjL AMANDA COBAUGH, DEPUTYC 07/09/2013 09:02 PM- Deputy Amanda Cobaugh, 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 Joel Nye, who accepted as"Adult Person in Charge"for Occupant at 6056 Edward Drive, Hampden Twp., Mechanicsburg, PA 17055. , 96am rl a AMANDA COBAUGH, DEPUTY SHERIFF COST: $76.60 SO ANSWERS, July 10, 2013 RbN R ANDERSON, SHERIFF (c)CountySuito Sheff,Tel&osoft,Inc. SHAPIRO &DeNARDO, LLC - ,F„`- t 1 �. BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 ” KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 r if' S`f l`� KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO:13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $131,762.79 in favor of the Plaintiff and against the Defendants,jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid $122,448.28 Interest Accrued $6,428.52 Late Charges $126.00 Escrow Advances $1,468.24 Property Inspection $28.00 Attorney Fees & Costs of Foreclosure $1,263.75 TOTAL $131,762.79 BY: to r Plaintiff AND NOW,judgment is entered in favor of the Plaintiff and inst nits and( �r damages are assessed as above in the sum of$131,762.79. g � `•�f Pro. rothy. 13-043262 N��C-t „ � SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CUMBERLAND COUNTY LLC successor by merger to Chase Manhattan Mortgage Corporation 13-3543 Civil 3415 Vision Drive Columbus, OH 43219 PLAINTIFF VS. Joel Nye and Debra Nye DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. SHAPIRO & DeNARDO, LLC Date: _(6 ctj 13 BY: Attorneys for Plaintiff Sworn to and subscribed before me this�_day of -� ,2013. Notary Public COM'e—'NWEALTH OF PENNSYLVANIA 1C0Mh90NWEAK 9 C F PENNSYLVANIA Notarial Seal —;031 Denise L.Semetti,Notary Public Denise ,,it�ary Public Upper Merlon T1ap.,Montgomery County upper mer-ot ,Y �ACrtlery county My Commission Expires July 22,2014 My Commissio�r ucpires JuEy 22,2014 Member.Pennsvlvanla Association of Notaries Member.Pennsvivania ASSOdation of Notaries SCRA 3.0 Pursmamf to Servicerme mb en Civil Relief A Last Name: NYE First Name: JOEL Middle Name: Active Duty Status As Of: Aug-09-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or histher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. A Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(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: S477EE80HOBlRDO SCRA 3.0 Status Report Purnuant to Servicemembers Civil Relief Act. Last Name: NYE First Name: DEBRA Middle Name: Active Duty Status As Of: Aug-09-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or histher 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 THATTHIS 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 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 Goldiers'amdSmimm'Oivi|Relief Act of1948). 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. |n the event the individual referenced above,m 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 contacfing that person's Service via the "dafenoe|ink.mirVRL:hn9:8vwvw.damnoe|ink.mi|/faq/pio/PC09SLDR.htm|. \f you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,puKitive provisions of the SCRA may be invoked against you. See 5OUSC App.8521(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 8Ordays preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty nn 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 omu81O only some of the active duty periods less than 3O 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]I 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(RPAo). 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 SCRAis Broader iO 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 000n Active Duty under this certificate. 8ORA protections are for Title 1Vand 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 o,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 uf 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 mn erroneous certificate mbeprovided. Certificate I[]: 54\/C2E5020B1C60 �� . SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-043262 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 23 7.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her,their attorney of record, if any, after the default occurred and at least(10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, July 30, 2013 to the following Defendants: Joel Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 Debra Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 Tiffany D to Christopher A. DeNardo, Esquire for Shapiro & DeNardo, LLC SHAPIRO&DeNARDO,LLC BY: CHRISTOPHER A. DeNARIDO,ESQUIRE,ATTORNEY I.D.NO. 78447 CAITLIN M. DONNELLY,ESQUIRE,ATTORNEY I.D.NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D.NO. 310530 3600 HORIZON DRIVE, SUITE ISO KING OF PRUSSIA,PA 19406 TELEPHONE: (610)278-,6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil vs. Joel Nye and Debra Nye DEFENDANTS NOTICE OF INTENTION TO TA DEFAULT UNDER Pa.R.C.P.-237.1 IMPORTANT NOTICE TO: Joel Nye DATE OF NOTICE: July 30,2013 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TMS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. _ 1 NOTLFICACION IMPORTANT'E Usted se encuentra en estado de rebeldia por no haber tornado la action requirida de sti parse en este caso. Al no tomar 1a action debida dentro de un tennino de diez(10) dial de la fecha de esta notificacion,el tribuna podra, sin necesidad de compararecer usted in torte o escuchar preuba. alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado irnmediatamente. Si usted no tiene abogado o si no tiene dinero sufciente para tal servicio,vaya en persona o llame por telefono a la oficina cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association. 32 South Bedford.Street. Carlisle, PA 17013 717-249-3166 PURSUANT TO THE.FAIR DEIST COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR'THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: .Joel Nye. 6056 Edgard Drive, Mechanicsburg, PA 17055 Debra Nye, 6056 Edward Drive, Mechanicsburg,PA '17055 S.HAPIRO & DeNARDO, LLC r Date:� BY: Att net's fo ai iff SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D.NO. 78447 CAITLIN M. DONNELLY,ESQUIRE,ATTORNEY I.D.NO. 311403 KASSIA FIALKOFF, ESQUIRE,ATTORNEY I.D.NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA,PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. ' Joel Nye and Debra Nye DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P.237.1 IMPORTANT NOTICE TO: Debra Nye DATE OF NOTICE: July 30, 2013 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber toma.do la action requirida de su parte en este caso. Al no tomar la action.debida dentro de un termino de'diez'(10) dias de la fecha de esta notification, el tribuna podia,sin necesidad de coinpararecer usted in torte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notification a un abogado immediatamente. Si usted no tierie abogado o si no tiene dinero suficiente Para tat servicio,vaya en persona o flame por telefono a la oficina cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Deferral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 1.701.3 71.7-249-31.66 PURSUANT TO THE FAIR DEIST COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TINS LAW FIRM IS DEEMED TO BE A)DEBT COLLECTOR ATTE1i PTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT'PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Joel Nye, 6056 Edward Drive, .Mechanicsburg,PA 1.7055 Debra.Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 SHAPIRO &DeNARDO,LLC Date: AA2, BY: _ A 4-4/- Att _ eys f or Plaint SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO:13-3543 Civil vs. Joel Nye and Debra Nye DEFENDANTS CERTIFICATE OF SERVICE 1, Christopher A. DeNardo, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Joel Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 Debra Nye, 6056 Edward Drive, Mechanicsburg, PA 17055 Date Mailed: SHAPIRO &DeNARDO, LLC 4��7 Date: BY: Attorneys for Plaintiff SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO:13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor(Plaintiff) is: JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation c/o CHE - JPMorgan Chase Bank,National Association 3415 Vision Drive Columbus, OH 43219 and that the last known addresses of the judgment debtors (Defendants) are: Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 SHAPIRO & DeNARDO, LLC Date: v` BY: Attorneys for Plaintiff 13-043262 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default 13 [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610)278-6800. r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary I [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610)278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: O Confessed Judgment () Other 3 . 3 , JPMorgan Chase Bank, National Association File No. V9 U successor by merger to Chase Home Finance Amount Due$131,762.79 LLC successor by merger to Chase Interest July 1, 2013 to December 4, 2013 is Manhattan Mortgage Corporation $2,975.46 PLAINTIFF Atty's Comm Costs vs. M171 C= Joel Nye and Debra Nye E`' DEFENDANT(S) ' -- TO THE PROTHONOTARY OF THE SAID COURT: f v-,� • The undersigned hereby certifies that the below does not arise out of a retail installment safes, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: Signature: Print Name: Christopher A. DeNardo, Esquire Address: 3600 Horizon Drive, Suite 150 nn King of Prussia, PA 19406 Attorney for: Plaintiff Ito (p p Supreme Court ID #PA Bar# 78447 sot� t ate. ?s pd 6? 6. so C0i/V6 I//26 tZ# gq r � a7� �� ALL THAT CERTAIN lot or piece of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Edward Drive which point is at the division line of Lots Nos. 157 and 158 on said plan; thence South 55 degrees 14 minutes East along aforementioned Edward Drive a distance of seventy-five (75) feet to a point at a point at the division line of Lots Nos. 156 and 157 on said plan; thence South 34 degrees 46 minutes West along said division line a distance of one hundred nineteen and eighty hundredths (119.80) feet to a point at land now or late of Kenneth Lantz; thence North 54 degrees 20 minutes West along the aforementioned lands of Lantz seventy-five and one hundredths (75.01) feet to a point at the line of Lots Nos. 157 and 158; thence North 34 degrees 46 minutes East along said division line a distance of one hundred eighteen and sixty-two hundredths (118.62) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 157 on plan of Noll Acres which plan is recorded in Plan Book 10, page 17 Cumberland County records. HAVING thereon erected a single family dwelling known and numbered as 6056 Edward Drive. BEING the same premises which Eileen Border, as Executrix of the Estate of Ashley Knosky, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed book 259, page 870, granted and conveyed unto Joel Nye and Debra Nye. I� 'is ',�':`_•� SHAPIRO &DeNARDO, LLC ,I,1,. BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 ► W CAITLIN M. DONNELLY, ESQUIRE, ` ; f� t�Lf' CEls''T y' ATTORNEY I.D. NO. 311403 tH SYLVANIA KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank,National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 6056 Edward Drive, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or Reputed Owner(s) Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 2. Name and address of Defendants in the judgment: Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219 The Bank of New York Mellon Trust Company, NA 101 Barclay Street 4th Floor West New York, NY 10286 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 6056 Edward Drive Mechanicsburg, PA 17055 e 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. SH DeNARDO, LLC BY: Christopher A. DeNardo, Esquire 13-043262 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE,ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D.NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-043262 JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS`:' successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Debra Nye 6056 Edward Drive Mechanicsburg, PA 17055 Your house(real estate) at: 6056 Edward Drive,Mechanicsburg,PA 17055 10-19-1604-089 is scheduled to be sold at Sheriffs Sale on December 4,2013 at: Cumberland County Sheriffs Office I Courthouse Square Carlisle, PA 17013 at I O:OOAM to enforce the court judgment of$131,762.79 obtained by JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank,National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)27 8-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 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 on page two of 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 TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 13-043262 ALL THAT CERTAIN lot or piece of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at a point on the Southern side of Edward Drive which point is at the division line of Lots Nos. 157 and 158 on said plan; thence South 55 degrees 14 minutes East along aforementioned Edward Drive a distance of seventy-five(75) feet to a point at a point at the division line of Lots Nos. 156 and 157 on said plan; thence South 34 degrees 46 minutes West along said division line a distance of one hundred nineteen and eighty hundredths(119.80) feet to a point at land now or late of Kenneth Lantz;thence North 54 degrees 20 minutes West along the aforementioned lands of Lantz seventy-five and one hundredths(75.01) feet to a point at the line of Lots Nos. 157 and 158; thence North 34 degrees 46 minutes East along said division line a distance of one hundred eighteen and sixty-two hundredths(118.62) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 157 on plan of Noll Acres which plan is recorded in Plan Book 10,page 17 Cumberland County records. HAVING thereon erected a single family dwelling known and numbered as 6056 Edward Drive. BEING the same premises which Eileen Border, as Executrix of the Estate of Ashley Knosky,by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed book 259,page 870, granted and conveyed unto Joel Nye and Debra Nye. a SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 _-� CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 : KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 - 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 `r TELEPHONE: (610)278-6800 %CD S &D FILE NO. 13-043262 4 t JPMorgan Chase Bank, National Association COURT OF COMMON PLEA§; successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO: 13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joel Nye 6056 Edward Drive Mechanicsburg, PA 17055 Your house (real estate) at: 6056 Edward Drive, Mechanicsburg, PA 17055 10-19-1604-089 is scheduled to be sold at Sheriffs Sale on December 4, 2013 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of$131,762.79 obtained by JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation 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 back to JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 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 on page two of 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 TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 13-043262 ALL THAT CERTAIN lot or piece of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Edward Drive which point is at the division line of Lots Nos. 157 and 158 on said plan; thence South 55 degrees 14 minutes East along aforementioned Edward Drive a distance of seventy-five(75) feet to a point at a point at the division line of Lots Nos. 156 and 157 on said plan; thence South 34 degrees 46 minutes West along said division line a distance of one hundred nineteen and eighty hundredths (119.80) feet to a point at land now or late of Kenneth Lantz; thence North 54 degrees 20 minutes West along the aforementioned lands of Lantz seventy-five and one hundredths (75.01) feet to a point at the line of Lots Nos. 157 and 158; thence North 34 degrees 46 minutes East along said division line a distance of one hundred eighteen and sixty-two hundredths (118.62) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 157 on plan of Noll Acres which plan is recorded in Plan Book 10,page 17 Cumberland County records. HAVING thereon erected a single family dwelling known and numbered as 6056 Edward Drive. BEING the same premises which Eileen Border, as Executrix of the Estate of Ashley Knosky, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed book 259, page 870, granted and conveyed unto Joel Nye and Debra Nye. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3543 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC SUCCESSOR BY MERGER TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff(s) From JOEL NYE AND DEBRA NYE i (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment,is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $131,762.79 L.L.: $.50 Interest JULY 1,2013 TO DECEMBER 4,2013 IS$2,975.46 Atty's Comm: Due Prothy:$2.25 Arty Paid:$225.35 Other Costs: Plaintiff Paid: Date: August 12,2013 David D.Buell,Prothonota (Sea]} AAI�U Deputy REQUESTING PARTY: Name: CHRISTOPHER A.DENARDO,ESQUIRE Address: SHAPIRO&DENARDO,LLC 3600 HORIZON DRIVE,SUITE 150 KING OF PRUSSIA,PA 19406 Attorney for:PLAINTIFF Telephone:610-278-6800 Supreme Court ID No.78447 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, y J{ NOV 1 2 P;'1 3: 31 ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, U[CBE RLA AND COUNTY ATTORNEY I.D. NO. 311403 PENNSYLVANIA AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-043262 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS successor by merger to Chase Home Finance CIVIL DIVISION LLC successor by merger to Chase CUMBERLAND COUNTY Manhattan Mortgage Corporation PLAINTIFF NO:13-3543 Civil VS. Joel Nye and Debra Nye DEFENDANTS CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on October 4, 2013, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. SHAPIRO &DENARDO, LLC 1J-�=-(3 Date: By: (44A1‘. Meghan Williams Legal Assistant 13-043262 W ce LL 1c103aa tulip>J CD CI II 1 n: N �CiantlaQ paaau;sa� z CQ z n LL 3uiipueu p iaadg A ill ,..0 be) o n�.. uoiik'uuguoj a.rn u2Ts Q i I ° " at uoi�L'ui ii uo rani a :t � m =LL 3 .I Q a) (i) ` allo O N O O a)0 j d . n 0 et r ] C{ 2 o r.' ' 7 1 4 W ta o i E U. a)a m � >.f Q > _N To D) V ?)12 16 a a 2'a) d N O C L N Q "m maa,m =U 0.<.,E2 . % „, E m ;c-.S. cc L °"°m0 m, m 0 x N`C h N y a) LL m=t)" ao co 6 a' o CI. C a) .2 N W a7 2 d C m 0 a) 2 c Y C o C as o E 8 z 0 i O c U 0 >; � a°iod 0 v m� m N o a„ '-m 04 E a' F- c O d'CC et vn m .o N A DODO z. a H )c 4 U 0 1:c` 5 N 0 N N "' , 0 GM U ,. X C N V=_ a) A Y7 O O^' Na) U 00 O O W E . •v) M >. N a) ¢ LY. C .N. a) �2 Z g p.0 3 .> o R,'F ° o.a o - 2 o r� n0 N b d o ›, o - 2UN ao"o d do a) x N 3 a 00 w e 2 = a -4 0 ti o 3 A o x t ca . 00000 ¢ tz . mc?w 3 I 'r' p pp E E L CD (...) .-. C.) °V Z E•' .4 a. G1 0. .r. o 0 LL N a) a) 0 a) a . 0 0 0 a a ,-.Ti y Z • a) 4 m 0 ...N M N ] o c o Z (N rt 0, 2 CO r o v Q ¢ 0 XI 0..o > 2 2 ' c a v LL -o E &,,, N O a) On ro 12..?3 Goad o aN co c a7 O = M j T E VIE E." C 13 N 0 a)4 a o 2 t/) M V1 x ,_ N M R U) (O 06 F-J a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff z r�, : I Jody S Smith 4'4,4 Chief Deputy )"(�t. Richard W Stewart r LE car ot Chorale,"Solicitor ;. r ,w u -�',"�utt�C i� E31:1;;;;:i;?.' PEN NS i IA f JP Morgan Chase Bank, NA vs. Case Number Joel Nye (et al.) 2013-3543 SHERIFF'S RETURN OF SERVICE 09/30/2013 05:06 PM - Deputy Shawn Gutshall, 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 6056 Edward Drive, Mechanicsburg, PA 17055, Cumberland County. 10/04/2013 09:10 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Joel Nye at 6056 Edward Drive, Hampden Twp., Mechanicsburg, PA 17055, Cumberland County. 10/04/2013 09:10 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Debra Nye at 6056 Edward Drive, Hampden Twp., Mechanicsburg, PA 17055, Cumberland County. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Christopher Denardo, on behalf of JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance, LLC successor by merger to Chase Manhattan Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $962.87 SO ANSWERS, January 06, 2014 RONIV ANDERSON, SHERIFF a. as' Ad. L'o. sa g-b' 3014, 7v na�t4S of ;t.e,^,B re t • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-3543 Civil Term 870,granted and conveyed unto Joel Nye and Debra Nye. JP MORGAN CHASE BANK,NA vs. JOEL NYE, Debra Nye Atty.: Christopher DeNardo ALL THAT CERTAIN lot or piece of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the Southern side of Edward Drive which point is at the division line of Lots Nos. 157 and 158 on said plan; thence South 55 degrees 14 minutes East along aforementioned Edward Drive a distance of seventy- five (75) feet to a point at a point at the division line of Lots Nos. 156 and 157 on said plan;thence South 34 degrees 46 minutes West along said division line a distance of one hundred nineteen and eighty hun- dredths (119.80) feet to a point at land now or late of Kenneth Lantz; thence North 54 degrees 20 minutes West along the aforementioned lands of Lantz seventy-five and one hun- dredths(75.01)feet to a point at the line of Lots Nos. 157 and 158;thence North 34 degrees 46 minutes East along said division line a distance of one hundred eighteen and sixty-two hundredths (118.62) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 157 on plan of Noll Acres which plan is recorded in Plan Book 10, page 17 Cumberland County records. HAVING thereon erected a single family dwelling known and numbered as 6056 Edward Drive. BEING the same premises which Eileen Border, as Executrix of the Estate of Ashley Knosky, by Deed dated June 30,2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed book 259,page 91 c PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. (--- ) L sa Marie Coyne, Edi or SWORN TO AND SUBSCRIBED before me this 25 day of O-ctoob)er, 2013 11,e0-ke Notary nw N';TAI'tIAL SEAL DEBORAH A COLLINS Notisy Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co.2020 Technolgy Pkwy e 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. 2013-3543 Civil Te This ad ran on the date(s)shown below: JP ORGAN CHASE B ,NA vs. JOEL NYE 10/13/13 Debra 10/20/13 ALL THAT CERTAIN lot or p ece of land 10/27/13 -Any: Christopher situate in the Township of Hampden,County .. of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: • • • , BEGINNING at a point on the Southern side of-Edward Drive which point is at the division line of Lots Nos.157 and 158 on said Sworn to/and s bscribed before me thi 11 day of November, 2013 A.D. plan;thence South 55 degrees 14 minutes East along aforementioned Edward Drive a ' n I distance of seventy-five(75)feet to a point ( 0 ., at a point at the division line of Lots Nos. il 156 and 157 on said plan;thence South 34 �� j lc degrees 46 minutes West along said division line a distance of one hundred nineteen and eighty hundredths(119.80)feet to a point at land now or late of Kenneth Lantz;thence North 54 degrees 20 minutes West along the CO!VIONw`ALTN OF PENNSYLVANIA aforementioned lands of Lantz seventy-five ''o*arial =:eai and one hundredths(75.01)feet to a point Ho!!'p'Lyn-,^` if,' t.^.?ary Public at the line of Lots Nos.157__a thence shn 1 ---x.,DP,uohin County North 34 degrees 46 minutes East along My Commission Expires Dec.12,2016 said division line a distance of one hundred MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES eighteen and sixty-two hundredths(118.62) feet to a point the PLACE nF BEGINNING. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which JPMorgan Chase 4th is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 12th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3543, at the suit of JPMorgan Chase Bank. NA against Joel Nye and Debra Nye is duly recorded as Instrument Number 201403353. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ) (-f day of Feb - , A.D. aON `( ha/Mil- u . (AZ0 1 .Dep y PA Recorder of Deeds Recorder of Deeds, berland County,Carlisle, My Commission Expires the First Monday of Jan.2018