HomeMy WebLinkAbout13-4315 Supreme Cou?rrt o Pennsylvania
COU O f COmmon leas For Prothonotary Use Only: f
C il, V r Sheet
• o Docket No:
CU BERLA County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S [E Complaint 0 Writ of Summons Petition
Q Transfer from Another Jurisdiction Q Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
JAMES B. NUTTER & COMPANY JAMESON A. WARREN & JENNIFER L. WARREN
T Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? 0 Yes El No (check one) Doutside arbitration limits
O
N Is this a Class Action Suit? 0 Yes [R No Is this an MDJAppeal? 0 Yes 0 No
A Name of Plaintiff /Appellant's Attorney:, POWERS, KIRN & JAVARDIAN, LLC
C.1jeck here if you have no attorney (are a Self - Represented 11 Sel I.,itigant)
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 0 Board of Assessment
0 Motor Vehicle Debt Collection: Other Board of Elections
0 Nuisance Dept. of Transportation
Premises Liability Statutory Appeal: Other
S 0 Product Liability (does not include
E mass tor[) � Employment Dispute:
Discrimination
0 Slander/Libel/ Defamation
0
C 0 Other: Employment Dispute: Other 0 Zoning Board
El
,
1 Other:
O MASS TORT
0 Asbestos
N 0 Tobacco
0 Toxic Tort - DES
0 Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS
0 Toxic Waste
Other: 0 Ejectment E] Common Law /Statutory Arbitration
B 0 Eminent Domain/Condemnation 0 Declaratory Judgment
0 Ground Rent 0 Mandamus
Q Landlord/Tenant Dispute Q Non - Domestic Relations
n Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY Q Mortgage Foreclosure: Commercial 0 Quo Warranto
Q Dental Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
Medical Other:
Other Professional:
Updated 1/1/2011
X
POWERS, KIRN & JAVARDIAN, LLC O F
Gregory Javardian, Esquire Id. No. 55669 ,�,,, p j �Y'C
�IJ f�k'
Mary F. Kennedy, Esquire Id. No. 77149 �u z3 4 d
Meghan K. Boyle, Esquire Id. No. 201661`1 ' `= �r
Sean P. Mays, Esquire Id. No. 307518 'NI) CnUi
Richard J. Nalbandian,111, Esquire Id. No. 312653 } j.�ft Y
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215- 942 -2090 ATTORNEYS FOR PLAINTIFF
JAMES B. NUTTER & COMPANY COURT OF COMMON PLEAS
4153 BROADWAY
KANSAS CITY, MO 64171 CIVIL DIVISION
PLAINTIFF
CUMBERLAND COUNTY
VS.
JAMESON A. WARREN, No.
JENNIFER L. WARREN COMPLAINT IN
1 ADAMS STREET MORTGAGE FORECLOSURE
ENOLA, PA 17025 -2802
DEFENDANT
CIVIL ACTION MORTGAGE FORECLOSURE
1. James B. Nutter & Company, (hereinafter referred to as "Plaintiff') is an Institution conducting
business under the Laws of the Commonwealth of Pennsylvania with a principal place of business
at the address indicated in the caption hereof.
2. Jameson A. Warren and Jennifer L. Warren, (hereinafter referred to as Defendants) are adult
individuals residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between Jameson A. Warren and Jennifer
L. Warren and itself as Mortgagee. The Mortgage dated October 3, 2001, was recorded on
January 29, 2002 in the Office of the Recorder of Deeds in Cumberland County in Mortgage
Book: 1747, Page: 2417. A copy of the Mortgage is attached hereto as Exhibit'A'.
4. The Mortgage secures the indebtedness of a Note executed by Jameson A. Warren on
October 3, 2001 in the original principal amount of $84,960.00 payable to Plaintiff in monthly
installments with an interest rate of 7.500 %. A copy of the Note is attached and made a part
hereof as Exhibit'B'.
5. The land subject to the mortgage is 1 Adams Street, Enola, PA 17025 -2802. A copy of the Legal
Description is attached as part of the Mortgage as Exhibit 'A' and incorporated herein.
6. Jameson A. Warren is the Record Owner of the mortgaged property located at
1 Adams Street, Enola, PA 17025 -2802. n-3
d y
2# a9.scxo101j
•
7. The Mortgage is now in default due to the failure of Defendant to make payments as they become
due and owing. As a result of the default, the following amounts are due:
Principal Balance $72,087.48
Interest to 7/10/2013 $3,732.75
Accumulated Late Charges $154.80
Escrow Deficit $927.01
Property Preservation $230.00
Cost of Suit and Title Search $550.00
Attorney's Fees $1,650.00
TOTAL $79,332.04
plus interest from 7/11/2013 at $14.81 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchase at Sheriffs sale. If
the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor
with Notice of Intention to Foreclose ("Act 6 Notice ") 41 P.S. §403 and Notice of Homeowners'
Emergency Mortgage Assistance ( "Act 91 Notice ") 35 P.S. §1680.403c.
10. The Act 6 Notice of Intention to Foreclose was required and was sent to the Defendants on
June 4, 2013, pursuant to 41 P.S. §403. A copy of the Notice is attached and made a part hereof
as Exhibit'C'.
11. The Mortgage is a Federal Housing Administration ( "FHA ") insured loan, and in accordance with
35 P.S. §1680.401c(a)(3) the notice provisions of 35 P.S. §1680.403c are not applicable and,
therefore, Plaintiff was not required to send the Act 91 Notice of Homeowners' Emergency
Mortgage Assistance.
WHEREFORE, Plaintiff requests the Court enter judgment in Mortgage Foreclosure for the sale of the
mortgaged property in Plaintiffs favor and against the Defendants, in the sum of $79,332.04 together with
the interest from 7/11/2013 at $14.81 per day, costs of suit and attorney's fees.
POWERS, KIRK & JAVARDIAN, LLC
By:
❑ Gregory Javardian, Esquire Id. No. 55669
❑ Mary F. Kennedy, Esquire Id. No. 77149
❑ eghan K. Boyle, Esquire Id. No. 201661
Sean P. Mays, Esquire Id. No. 307518
Richard J. Nalbandian, III, Esquire Id. No. 312653
Attorneys for Plaintiff
POWERS, KIRN & JAVARDIAN, LLC
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id. No. 77149
Meghan K. Boyle, Esquire Id. No. 201661
Sean P. Mays, Esquire Id. No. 307518
Richard J. Nalbandian,111, Esquire Id. No. 312653
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215- 942 -2090 ATTORNEYS FOR PLAINTIFF
JAMES B. NUTTER & COMPANY COURT OF COMMON PLEAS
4153 BROADWAY
KANSAS CITY, MO 64171 CIVIL DIVISION
PLAINTIFF
CUMBERLAND COUNTY
VS.
No.
JAMESON A. WARREN,
JENNIFER L. WARREN COMPLAINT IN
1 ADAMS STREET MORTGAGE FORECLOSURE
ENOLA, PA 17025 -2802
DEFENDANT
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 defense 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717 - 249 -3166
800 - 990 -9108
til
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.0 § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF.
IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO
CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
EXHIBIT `A'.
t E0
111'( U 'i w C.OU14 T Y -PA
'02 JAN 29 flM 10 39
FIRST FINANCIAL TITLE AGENCY
Aft r recor ti n return to; 406 1.IppiNCOTT DRIVE -SUITE I
Ja s 8 ut r & Company MARLTON, NJ 08053
410 r s ay
Kansas y, Mlssourl 64111
.
Kansas
' ber;
(space Above This Lino For Recordin Datdi
Commonwealth of FHA Case No.
Pennsylvania MORTGAGE 441- 5059.703 203b
PA 200508
I THIS MORTGAGE,( "Seourtty instrument ") is given an OCTOBER 3, 2001 The Mortgagor
i is JAMESON A. WARREN
, A MARRIED MAN
AM JMMIFSR L. ViA MEN
("Borrower").
This Security Instrument is given to James B. Nutter & Company, which Is organized and existing under
the laws of the State of Missouri, and whose address Is 4163 Broadway, Kansas City, Missouri 64111
{"Lender "), Borrower owes Lender the principal. sum, of
EIGHTY FOUR THOUSAND NINE RMWRED SIXTY & OD/2-00
Dollars (U.S. $ 84, 960.00 , }, This debt is evidenced by Borrower's note .dated the same
date as this Security Instrument ( "Note "), which provides for monthly peymonts, with the foil debt, if
not paid earlier, due and payable on xovnoXR 1, 2091 . This Security Instrument secures to
Lender: (a) the repayment of the debt evidenced by the Note, with Interest, and all renewals, extensions
and modifications of the Note; (b) the payment of all other sums, with interest, advanced under
paragraph 7. to protect the security of this Security Instrument; and (c) the performance of Borrower's
covenants and agreements under this Seeurlty Instrument and the Note. For this purpose, Borrower
does hereby mortgage, grant and convey to the Lender the following described property located in
C MEERWM County, Pennsylvania:
ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE IMPROVEMENTS THEREON ERECTER
SITUATE IN THE TOWNSHIP OF EAST PANNSBORO, COMM OF CUMBERLAND, CoMMONWBALTH
O8' PRIMSYLVA=A, BOUNDED AND DESCRIBED IN AC'CCRUANCB WITH A SVRVRI' AND PLAN
THEREOP MADE BY LRNBST J. WALRLSR, PROFZSSIONAL WGINELR, DATED SEPTSHBER 2,
1970, AS FOLLOWSs BEGINNING ,AT A POINT ON THS NORTHERLY SIDS OF : ADAMS STREET,
BEING 214 F93T IN A WESTWARDLY VIRECTYON BY SAME VItOM TIM CENTER. LINE OF SOUTH
SNOLA DRIVE AS LAID OUT ON A PLAN OF LOTS OF JOHN Q. ADAM D JOSHPH DYNE,
RECORDED IN THE RECORDER OF .DEEDS OFFICE, CUMBEW+A ND COMM, COU IN PLAN BOOK 1.,
PAGE 171 THENCE SOUTH 78 DEGREES 30 MINUTES ;?PEST ALONG THE LINO OF SAID LAST
MENTIONED. LOT 150 PERT TO MONROE STRE9T1 T=CE NORTH 78 DEGREES 30 MINUTES
RABT ALONG MONROR STREET) 50 PELT TO A 15 FOOT ALTAYJ THI = SOUR 11 DSQREEB
30 MINUTES EAST ALONG SAID ALLEY, 150 FEET TO THE PLACE OF Bzan MQINt3.
SUBJECT To At,L "STRICTIONS, RESERVATIONS & EABSKANTS NOW OF RECORD, IS ANY.
which has the address of 1 ADAMS STAHET, SNOLA, M ", clteb
Pennsylvania INW (ZIpCcdof ( "Property Udrsss ");
Vomm Page 1 of 8 FHA Pennsylvenla Wlortgegs . 4186
8K i 747PG24 17
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and
additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this
Security Instrument as the "Property ".
BORROWER COVENANTS that Borrower is la.wfuliy seized of the estate hereby conveyed and has
the right to mortgage, grant and convey the Property and that the Property is unencumbered, except
for encumbrances of record. Borrower warrants and will defend generally the title to the Property
against all claims and demands, sub)eot to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non- uniform
covenants with limited variations by jurisdiction to constitute a uniform security Instrument covering
real property, ,
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS.
1. Payment of principal, Interest and Late Charge. Borrower shall pay when due the principal of,
and interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly ,Payment of Taxes, insurance and other Charges. Borrower shall Include In each
monthly payment, together with the principal and interest as set forth in the Note and any late charges,
a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold
payments or ground rents on the.Property, and (c) premiums for Insurance required under paragraph
4. In any year In which the Lender must pay a mortgage insurance premium to the Secretary of Housing
and Urban Development ( "Secretary "), or in any year in which such premium would have been required
If Lender still hold the Security Instrument, each monthly payment shall also include either: (i) a sum
for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (10 a monthly
charge Instead of a mortgage insurance premium if this Security Instrument is held by the Secretary,
in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the
Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow
Funds ".
Lander may, at any time, collect and hold amounts for Escrow Items In an aggregate amount not
to exceed the maximum amount that may be required for Borrower's escrow account under the Real
Estate - Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 of seq. and Implementing
regulations, 24 CFR Part 3500, as they may be amended from to time ( "RESPA "), except that the
cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the
Borrower's payments are available In the account. may not be based on amounts due for the ,mortgage
insurance premium.
If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by
RESPA, Lender shall account to Borrower for the excess funds as required by RESPA, If the amounts
of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may
notify the Borrower and require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional sscurlty for all sums secured by this Security
Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shell
be credited with the balance rernalning for all installment items (a), (b), and (a) and any mortgage
Insurance premium Installment that Lender has not become obligated to pay to the Secretary, and
Lender shall promptly refund any excess funds to Borrower, Immediately prior to a foreclosure sale of
the Property or its acquisition by Lender, Borrower's account shall be credited. with .any balance
remaining for all installments for Items (a), (b), and (c).
3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as
follows;
V00906 Pago 2 of a
BK 1747PG24 18
Eirst, to the mortgage Insurance premium to be paid by Lender to the Secretary or to the monthly
charge by the Secretary Instead of the monthly mortgage insurance premium;
Sguond.• to any taxes, special assessments, leasehold payments or ground rants, and fire, flood
and other hazard Insurance premiums, as required;
JbW, to interest due under the Note;
Fourth, to amortization of the principal of the Note; and
M to late charges due under the Note.
4. Fire, Flood and Other Hazard insurance, Borrower shall Insure all Improvements on the Property,
a whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, .
Including fire, for which Lender requires Insurance. This Insurance shall be maintained in the amounts
and for the periods that Lender requires. Borrower shall also Insure all improvements on tSe Property,
whether now in existence or subsequently erected, against loss by floods to the extent required by the
Secretary. All insurance shall be carried with companies approved by Lender. The Insurance policies and
any renewals shall be held by Lender and shall include loss payable clauses in favor of, and In a form
acceptable to, Lender.
In the event of toss, : Borrower shall give Lender immediate notice by mail. Lender may make proof
of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and
directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender Jointly.
All or any.part of the insurance proceeds may be applied by Lender, at its option, either (a) to the
reduction of the indebtedness unifier the Note and this Security Instrument, first to any delinquent
amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the
restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not
extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or
change the amount of such payments. Any excess insurance proceeds over an amount required to pay
all outstanding :Indebtedness under the Note and this Security Instrument shall be paid to the entity
legally entitled thereto.
In the event of foreclosure of this Security Instrument or other transfer of title to the Property that
extinguishes the indebtedness, all right, title and Interest of Borrower in and to Insurance policies in
force shall pass to the purchaser.
S. occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument (or within sixty days of a
later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal
residence for at least one year after the date of occupancy, unless tender determines that requirement
will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond
Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not
commit waste or destroy, damage or substantially change the Property or allow the Property to
deteriorate, reasonable weer and tear excepted. Lander may inspect the Property if the Property is
vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and
preserve such vacant or abandoned Property. Borrower shall also be In default if Borrower, `during the
loan application process, gave materially false or inaccurate Information or statements to Lender (or
failed to provide Lender with any material Information) in connection with the loan evidenced by the
Note, including, but not limited to, representations concerning Borrower's occupancy of the Property
as a principal residence. if this Security instrument Is on a leasehold, Borrower shall comply with the
provisions of the lease: If Borrower acquires fee title to the Property, the leasehold and fee title shall
not be merged unless Lender agrees to the merger In writing.
V06DW Page s of s
ER 1747K241 9
III I 11111mg-o lo
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, In
connection with any condemnation or other taking of any part of the Property, or for conveyance In
place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount
of the Indebtedness that remains unpaid under the Mote and this Security Instrument. Lender shall apply
such proceeds to the reduction of the indebtedness under the Note and this Security instrument, first
to any delinquent amounts applied In the order provided in paragraph 3, and then to prepayment of
principal. Any application of the proceeds to the principal shall not extend or postpone the due date
of the monthly payments, which are referred to In paragraph 2, or change the amount of such'
payments, Any excess proceeds over an amount required to pay all outstanding indebtedness under the
Note and this Security Instrument shall be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's flights in the Property. Borrower shall pay all
govemmentsi or municipal charges, fines and impositions that are not included In paragraph 2. Borrower
shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay
would adversely affect Lender's interest In the Property, upon Lender's request Borrower shall promptly
furnish to Lender receipts evidencing these payments.
If Borrower falls to make these payments or the payments required by paragraph 2, or falls to
perform any other covenants and agreements contained In this Security Instrument, or there Is a legal
proceeding that may significantly affect Lender's rights In the Property {such as a proceeding in
bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever
Is necessary to protect the value of the Property and Lender's rights In the Property, including payment
of taxes, hazard Insurance and other Items mentioned In paragraph 2.
Any amounts disbursed by Lender under this paragraph shall become an additional debt of
Borrower and be secured by this Security Instrument, These amounts shall bear interest from the date
of disbursement, at the Mote rate, and at the option of Lender, shall be Immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security . Instrument unless
Borrower: le) agrees in writing to the payment of the obligation secured by the lien In a manner
acceptable to Lender; (b) contests in good falth the lien by, or defends against enforcement of the lien
In, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien: or
(c) secures from the holder of the lien an agreement sadsfaotory to Lander subordinating the lien to this
Security Instrument, if Lender determines that any part of the Property is subject to a lien. which may
attain priority over this Security Instrument, Lender may give Borrower a notice Identifying the lien.
Borrower shall satisfy the lion or take one or more of the actions set forth above within 10 days of the
giving bf notice.
S. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceleration of Debt.
la) Default. Lender may, except as limited by regulations issued by the Secretary, in the case
of payment defaults, require Immediate payment in full of all sums secured by this Security
Instrument If:
(1) Borrower defaults by failing to pay In full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment, or
( €i) Borrower defaults by failing, for a period of thirty days, to perform any other
obligations contained In this Security instrument.
ib) sale Without Credit Approval. Lander shall, if permitted by applicable taro (including Section
341(d) of the Garn -St. Germain Depository institutions Act of 1982, 12 U.S.C. 1701 j -3(d))
and with the prior approval of the Secretary, require immediate payment in full of all sums
secured by this Security Instrument If;
VOOD"s Pepe a of B
BK 1 747PG2420.
3
(1) All or part of the Property, or a beneficial Interest in. a trust owning all or part of the
Property, Is sold or otherwise transferred (other then by devise or descent), and
(11) The Property Is not occupied by the purchaser or grantee as his or her principal
residence, or the purchaser or grantee does so occupy the Property but his or her credit
has not been approved In accordance with the requirements of the Secretary.
(c) No Waiver, If circumstances occur that would permit Lender to require immediate payment.
1 in full, but Lender does not require such payments; Lender does not waive its rights with
i respect to subsequent events.
(dl Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will
limit Lender's rights, In the case of payment defaults, to require Immediate payment. in full and
foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not
permitted by regulations of the Secretary.
(e) Mortgage Not insured. Borrower agrees that If this Security Instrument and the Note are not
determined to be eligible for insurance under the National dousing Act within 60 days from the
date hereof, Lender may, at Its option, require immediate payment in full of all sums secured
by this Security instrument. A written statement of any authorized agent of the Secretary dated
:subsequent to 60 days from the date hereof, declining to Insure this Security instrument and the
Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this
option may not be exercised by Lender when the unavallablilty of Insurance Is solely due to
Lender's failure to rernit a mortgage Insurance premium to the Secretary.
10. Reinstatement. Borrower has a right to be reinstated If Lender has required immediate payment N
In full because of Borrower's failure to pay an amount due under the Note or this Security Instrument.
This right applies aven after foreclosure proceedings are instituted. To reinstate the Security Instrument,
Borrower shall tender In a lump sum all amounts required to bring Borrower's account current including,
to the extent they are obligations of Borrower under this Security instrument, foreclosure costs and
reasonable and customary attorneys' fees and expenses properly associated with the foreclosure
proceeding. Upon reinstatement by Borrower, this Security instrument and the obligations that it
secures shall remain in effect as if Lander had not required immediate payment in full. However, Lender
Is not required to permit reinstatement If: (1) Lender has accepted reinstatement after the
commencement of foreclosure proceedings within two years immediately preceding the commencement
of a current foreclosure proceeding, 111) rainstatement. will preclude foreclosure on different grounds In
the future, or (Iii) reinstatement will adversely affect the priority of the lien created by this Security
Instrument.
11. Borrower Not Released: Forbearance By Lender Not a Waiver. Extension of the time of payment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to
any successor In interest of ; Borrower shall not operate to release the liability of the original Borrower
or Borrower's successor in Interest. Lender shall not be required to commence proceedings against any
successor in Interest or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security instrument by reason of any demand made by the original Borrower or
Borrower's successors in Interest. Any forbearance by Lander in exercising any right or remedy shall
not be a waiver of or_preciude .the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co- Signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of lender and
Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements. shell be
joint and several.. Any Borrower who co -signs this Security Instrument but does not. execute the Mote:
(e) is co- signing this Security instrument only to mortgage, grant and convey that Borrower's interest
V06DM Paps is of a
OK 174 7PG242 I
w
in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the
sums secured by this Seourlty Instrument; and {c) agrees that Lander and any other Borrower may agree
to extend, modify, forbear or make any accommodations with regard to the terms of this Security
Instrument or the Note without that Borrower's consent.
13. Notices. Any notice to Borrower provided for In this Security Instrument shall be given by
delivering it or by mailing It by first class mail unless applicable law, requires use of another method. The
notice shall be directed to the Property Address or any other address Borrower designates by notice
to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or
any address Lender designates by 'notice to Borrower. Any notice provided for In this Security
instrument shall be deemed to have been given to Borrower or Lender when given as provided in this
paragraph.
14. Governing Law;.Severabillty. This Security Instrument shall be governed by Federal law and
the law of the jurisdiction in which the Property is located. In the event that any provision or clause of
this Security instrument or the Note conflicts with applicable law, such conflict shell not affect other
provlslons of this Security Instrument or the Note which can be given effect without the confiloting
provlelon. To this end the provisions of this Security Instrument and the Nola are doctored to be
severable,
16, Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
18, Hazardous Substances. Borrower shalt not cause or permit the presence, use, disposal,
storage, or release of any Hazardous Substances on or In the Property.. Borrower shall not do, .nor allow
anyone else to do, anything affecting the Property that Is in violation Of any Environmental Law. The
preceding two sentences shad not apply to the presence, use, or storage on the Property of small
quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential
uses and to maintenance of the Property,
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 Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower
learns, or in notified by any governmental or regulatory authority, that any removal or other remedlation
of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all
necessary remedial actions in accordance with Environmental Law.
As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or
hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other
flammable or toxic petroleum products, toxic pssticides and herbicides, volatile solvents, materials
containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16,
"Envlmnmentai Law" means federal laths and. laws of the jurisdiction where the Property is located that
relate to health, safety or environmental protection.
NON- UNIFORM COVENANTS.: Borrower and Lender further covenant and agree as follows:
1.7, Assignments of Rents. Borrower unconditionally assigns and transfers to Lander all the rents
and .revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and
revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents:.
However, prior to Lender's notice to .Borrower of 'Borrower's breach of any covenant or agreement In
the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as
trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute
assignment and not an assignment for additional security only.
If Lender gives notice of brRenh to Borrower: (a) all rents received by Borrower shat( be hold by
YOSD9t0 Pop a of a
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Borrower as trusted for benefit of Lender only, to be applied to the sums secured by the Security
Instrument, (b) Lender she be entitled to collect and recelvo sit of the rents of the Property; and (c)
each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's
written demand to the tenant.
Borrower has not executed any prior assignment of the rents and has, not and will not perform any
act that would prevent tender from exercising its rights under this paragraph 17,
Lender shall not be required to enter upon, take control of or maintain.the Property before or after
giving notice of breach to Borrower. However, fender or a judicially appointed receiver may do so at
any time there Is a breach. Any application of rents shell not cure or waive any default or Invalidate any
other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt
secured by the Security instrumment is paid in full.
l 18. Foreclosure Procedure. if Lender requires Immediate payment to full under paragraph 9, Lender
may foreclose this Security instrument by judicial proceeding. Lender shall be entitled to collect all
expenses Incurred In pursuing the.rema Iles provided in this paragraph 18, including, but not limited to,
attorneys' fees and costs of We evidence.
if the Lender's interest in this Security instrument is held by the Secretary and the Secretary
requires Immediate payment In full under Paragraph 9, the Secretary may invoke the nonjudicial power
of sale provided In the Singte Family Mortgage Foreclosure Act of 1994 ( "Act) (12 U.S.C. 3751 et segr )
by .requesting a foreclosure commissioner. designated under the Act to commence foreclosure and to
sell the Property as provided in the Act. Nothing in the preceding sentence aheil deprive the Secretary
of any rights otherwise available to a Lender under this Paragraph 18 or applicable law.
19. Release. Upon payment of all sums secured by this Security instrument, this Security
instrument and the estate conveyed shall terminate and become void, After such occurrence, Lender
shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any
recordation costs.
20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error
or,defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any
present or future laws providing for stay of execution, extension of time, exemption form attachment,
levy and sale, and homestead exemption.
21. Reinstatement Period. Borrower's time to reinstate provided ;n - paragraph 10 shall extend to
one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security
Instrument.
22.. Purchase Money Mortgagei if any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to tha Property, this Security Instrument shall be a purchase money mortgage.
28. interest Rate After Judgment. Borrower agrees that the Interest rate payable_ after a Judgment
Is entered on the Note or In an action of mortgage foreclosure.shatl be the rate payable from time to
time under the Note.
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded
together with this Security Instrument, the covenants of each such rider shall be Incorporated into and
shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s)
were a part of this Security instrument. (Check applicable box(es)).
❑ Condominium Rider ❑ Growing Equity Rider ❑ Other [specify]
❑ Planned Unit Development Rider ❑ Graduated Payment Rider
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BY SIGNING BELOW, Borrowor accepts and agrees to the terms contained In this Security
instrument and In any rider(s) executed by Borrower and recorded with it.
Haase
..--�
MUM A. WARREN - Borrower
(Seal)
-Borrower
(Seal)
Borrower (Seal)
Borrower
(Seal)
- 6orrower (Sent)
- sorrower
w (Seat)
:�8231tt R • borrower (Seal)
STCINIMt SOL1vLY TO L4AIVE MARITAL 7tYt�HTS - Borrower
Certificate of Residence
��� GUY , do hereby certif that the correct address
of the within -named Lender is ' a �bo? 3�$ t�,C�° HR" >� ap s �kM O SW r over DR 14090.
Witness my hand this 28th day of 88pTEM ER, 2001.
R
VERA 0M Agent of Lander
COMMONWEALTH OF PENNSYLVANIA, dil(Mj$jML �RND County sa:
On this, 3rd day of OCTOBER, 2001 , before me, the
undersigned officer, personally appeared
R7AM SON A. WARREN
, A MAt MED MAIN
MM C21I1IFIR L. WARRSN
person whose name Z8 subscribed to the within instrument and acknowledged that
Y8 executed the same for the. purposes herein contained.
N WITNESS WHEREOF, I hereunto set my hand and ficial sea)....��j
,nY. Co.mmi sion Ex I
t.P •h R o:i•,i N p T A S i A t$ E A L
p:a � : f lNADETIE fd. REFPEVINOER, ROTARY PUBLIC
Y; ' F 1uc�' ?'.:IC£BUttq, CU4(BERLAND Co., PA
i r - • tilE$ NOVEtdBER 2d, 2003
D My Cap DSIDN EXP ' of Officer
{',1.• . v461j914t'jo Page 8 of o
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EXHIBIT `B'
I
Multistate NOTE FHA Case No.
I 441 - 6693059 -703 203b
i
i OCTOBZR 3, 2001 1 At)W STRR$f, SIMLA, FA 17025
l
WM►r 1p- wty+ladm4
1. PAFIT19S
".Borrower" means each person signing at the and of this Note, and the person's successors and assigns. "Lander'
means Jamas B, Nutter & Company, a Missouri Corporation, 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
SZQR?Y Ir0[rR TtOJVU= 2tM ==Mw aim i 00/104
Dollars (U.S. $ 84,95D.00 ), plus Interest, to the order of Lender. Interest will be charged on unpaid principal,
from the data of disbursement of the loan proceeds by Lander, at the rate of sE'VSa AEI t�NS - irALg
percant f 7.500 96) per year until the full amount of principal has been paid.
3. PROMISE TO PAY.SECURED
Borrower's Prom tas to pay is secured by a mortgage, dead of trust or similar security instrument that la dated the
same date as this Note and called the "Security Instrument ". The Security Instrument protects the Lander from fosses
Which might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
IA) Time
Borrower shall make a payment of principal end interest to Lander on the first day of each. month beolnning
on VIaMMIR, 2041 Any principal and Interest remaining on the first day of taonstss%R, 3031
will be due on that date, which is celled the "Maturity Date
(B) Place
Payment shall be made at 4153 Broadway, Kansas C4ty, Missouri 64111 or at such place as Lander may
designsts in writing by notice to Borrower,
(C) Amount
Each monthly payment of principal and Interest will be In the amount of U.S. $ 554.00 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 8eowlty Instrument.
ID) A(longe to this Note for payment adjustments
if sn ailongs providing for payment adjustments is executed by Borrower together with this Note, the
covenants of the a longe shall be Incorporated Into and shall offend and supplement the covenants of this Note as If
the allongs were a part of this Note. (Check applicable box]
❑ Graduated PaymentAlionge ❑ Growing Equity Allonge ❑ Other (specify)
S. BORROWER'SAIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, In whole or In part, without charge or pans ty, 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 Lander agrees In writing to those changes.
S. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdus Payments
It tender has not received the full monthly payment required by the Securty Instrument, as described in
:Paragraph 4(C) of this Note, by the and of fifteen calendar days after the payment Is due, Lender may collect a late
charge in the amount of 8*VR percent ( 4. 9b) of the overdue smount
of each payment.
to) Default
H Borrower defaults by (ailing to pay In full any monthly payment, then tender may, except as limited by
r egulations of the Secratery.ln the case of payment defaults, require intmedlate payment In fWl of the principal balance
remaining slue and all accrued interest. Lander may choose not to exercise this option without waiving its rights In the
event of any subsequent default. In many clrcumstsntss 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 Nate, "Secretary" means the Secretary of Housing and urban
Davelopment or his or her designee,
(C) Payment of Costs rind 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 extant not prohibited
by applicable law. Such fees and costs shall bear Interest from the dais of disbursement at the same rate as the
prlhoipal of this Note.
V06DIO MA rolutdstete Rxed Rats Prop 10195
Pace r of 2
_
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of
of dishonor. 'Presentment" means the right to require t artdor to demand payment of amounts duet and
Nodos of
dishonor" means the right to require Lender to give notice to other persona that amounts due have not been paid,
a- GIVING OF NCTICEs
Unless appt(cable requires a dIfferent .mathod any notice that must be given to Borrower under this Note will
be given by delivering it or by mailing it by Bret class Mail to BorrOWer at the property address above or at a different
address If Borrower has given Lander A notice of tiarrowar's different address.
Any notice that must be given to Lando under this will be given by first class mail to Lender at the address
stated In paragraph 4(8) or at a different address If BotroWer Is given a notice of that different address.
9. OBLIOATtONS Of PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person Is 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 those o6ligadona. Including the
obligatlons of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made In thle
Note. Lander 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.
(seat)
JAM8aC27 A. WARRM Borrower Borrower
Seal
{snot) {Seal!
Bo
war Borawar
{Seal) iSeail
Borrower . Borrower
(Seal) (Seal)
Borrower Borrower
i t
:r
vob0M
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EXHIBIT `C'
f
POWERS, KIRN, & JA VARDIAN, LLC 1310 Industrial Boulevard
2 "d Floor /Suite 202
June 4, 2013 Southampton, PA 18966
Phone: (215) 942 -2090
Via: First Class and Certified Mail Fax: (215) 942 -8661
Jameson A. Warren Jennifer L. Warren
1 Adams Street 1 Adams Street
- Enola, PA 17025 Enola, PA 17025
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE currently held by James B. Nutter & Company, (hereinafter
"Lender "), on your property located at 1 Adams Street, Enola, PA 17025, loan number
IS IN SERIOUS DEFAULT because you have not made the monthly payments from:
12/1/2012 — 6/1/2013, as follows:
Monthly Charges 12/1/2012- 6/1/2013 $5,418.00
@ $774.00
Late Charges 2/1/2012- 6 /1/2012 $154.80
@ $30.96
Property Preservation $230.00
TOTAL DUE: $5,802.80
The total amount now required to cure this default, or in other words, get caught up in
your payments, as of the date of this letter is $5,802.80. Please also be advised that the original
lender of your mortgage was James B. Nutter & Company.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by
paying to your Lender the above amount of $5,802.80 plus any additional monthly payments and
late charges which may fall due during this period. Such payment must be made either by cash,
cashier's check, certified check, or money order and made to: James B. Nutter & Company
4153 Broadway Kansas City MO 64111 Attention: Robert Bell
If you do not cure the default within THIRTY (30) DAYS, your Lender intends to
exercise its right to accelerate the mortgage payments. This means that whatever is
owing on the original amount you borrowed will be considered due immediately and you may
lose the chance to pay off the original mortgage in monthly installments. If full payment of the
amount of default is not made within THIRTY (3 0) DAYS, your Lender also intends to start a
lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to payoff the mortgage debt. If the default is not cured
within thirty (30) days of the date of this letter but is cured before legal proceedings begin
against you, you will still have to pay the reasonable attorney's fees that are actually incurred, up
Certified Artide
4 7196 9008 9040 1765 0862
f -
• - � SENDERS RECORD
to $50.00, and any reasonable costs of proceeding to foreclosure that are actually incurred to the
date of payment. However, if legal proceedings are started against you, you will have to pay the
reasonable attorney's fees even if they are over $50.00, plus all of the reasonable costs actually
incurred. Any attorney's fees will be added to whatever you owe on your mortgage, which may
also include reasonable attorney's costs. You may find out at any time exactly what the required
payment will be by calling James B. Nutter & Company at the following number: 1 800 315-
7334 If you cure the default within the thirty -day period, you will not be required to pay
attorney's fees.
You may also be sued personally for the unpaid principal balance and all other sums due
under them If you have not cured the default within the thirty (30) - day period and
foreclosure proceedings have begun, you still have the right to cure the default and prevent the
sale at any time up to one hour before bidding starts at the Sheriff's foreclosure sale You may
do so by paying the total amount of the unpaid monthly payments plus any late or other charges
then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale
(and perform any other requirements under the mortgage). It is estimated that the earliest
that such a Sheriffs sale could be held would be approximately 12/1/2013 A notice of the date
of Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the
default will increase the longer you wait. You may find out at any time exactly what the required
payment will be by calling James B. Nutter & Company at the following number: 1 (800) 315-
7334 x 7022. This payment must be in cash, cashier's check, certified check, or money order
and made payable to James B. Nutter & Company at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged
property and your right to remain in it. If you continue to live in the property after the Sheriff s
sale, a lawsuit could be started to evict you.
You have the right to cure after acceleration and the right to bring a court action or assert
in any foreclosure proceeding, the non - existence of a default or any other defense you have to
acceleration and the sale of the property.
"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 ALSO 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'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE
OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. THE TRANSFEREE TO
WHOM YOU TRANSFER THE PROPERTY MAY HAVE THE RIGHT CURE AS WELL. CONTACT
YOUR LENDER TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT
EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF."
Ifyou cure the default, the mortgage will be restored to the same position as ifno default
had occurred. However, you are not entitled to this right to cure your default more than three
times in any calendar year.
Very truly yours,
D regory Javardian, Esquire Id. No. 55669
DMary F. Kennedy, Esquire Id. No. 77149
DMeghan K. Boyle, Esquire Id. No. 201661
D do P Mays, Esquire Id. No. 307518
chard J. Nalbandian, III, Esquire Id. No. 312653
POZLEg4, KIXrAres9AVARDI,W, LLC
Attorney for Lender
Notice Pursuant to Fair Debt Collection Practices Act attached.
IN THE EVENT THAT YOU ARE SUBJECT TO AN AUTOMATIC STAY ISSUED BY A
UNITED STATES BANKRUPTCY COURT OR THE REFERENCED DEBT HAS BEEN
DISCHARGED IN BANKRUPTCY, THIS COMMUNICATION IS FOR COMPLIANCE
AND INFORMATIONAL PURPOSES ONLY AND IS NOT INTENDED TO BE AN
ATTEMPT TO COLLECT A DEBT.
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
1. This is an attempt to collect a debt and any information obtained will be used for
the purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30)
days after receipt of this notice, the`debt will be assumed to be valid by our offices.
3. If you notify our offices in writing within thirty (30) days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4. If you notify our offices in writing within thirty (30) days of receipt of this notice,
our offices will provide you with the name and address of the original creditor, if
different from the current creditor.
a
VERIFICATION
The undersigned hereby states that the statements made in the foregoing pleadings are true and
correct to the best of his /her knowledge, information and belief. The undersigned understands that the
statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
Name: _Bruce Huey
Title: Vice President
James B. Nutter & Company
Warren, Jameson A.
13 -0298
c'II FID— , Five
POWERS, KIRN & JAVARDIAN, LLC M i t i p " h ' T IN 0 F� y
Gregory Javardian, Esquire Id. No. 55669 ;� 6 1 " ' !
Mary F. Kennedy, Esquire Id. No. 77149 �' `' ` 't + i ,
Meghan K. Boyle, Esquire Id. No. 201661 f'.U1" TER L iii D C 0 U 14 T V
Sean P. Mays, Esquire Id. No. 307518 ; L- '1J5 � �i
Richard J. Nalbandian, III, Esquire Id. No. 312653
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215- 942 -2090 ATTORNEYS FOR PLAINTIFF
JAMES B. NUTTER & COMPANY COURT OF COMMON PLEAS
4153 BROADWAY
KANSAS CITY, MO 64171 CIVIL DIVISION
PLAINTIFF
CUMBERLAND COUNTY
VS.
No. J3
JAMESON A. WARREN,
JENNIFER L. WARREN COMPLAINT IN
1 ADAMS STREET MORTGAGE FORECLOSURE
ENOLA, PA 17025 -2802
DEFENDANT
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 2439400 extension 2510 or 800 8225288 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
THESTEPS REQUIRED BY THIS NOTICE THIS PROGRAM IS FREE.
Date Respectfully submitted,
❑Gregory Javardian, Esquire Id. No. 55669
[]Mary F. Kennedy, Esquire Id. No. 77149
❑Meghan K. Boyle, Esquire Id. No. 201661
1 jean P. Mays, Esquire Id. No. 307518
ichard J. Nalbandian,111, Esquire Id. No.312653
Attorneys for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion
Program
Date: Financial Worksheet
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
CUSTOMER/ PRIMARY APPLICANT
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:
Number of people in household How long:
CO- BORROWER
Mailing Address:
City: State
Zip:
Phone Numbers: Home:
Office: Cell:
Other:
Email:
Number of people in household How long:
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
„A 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 #l: Model
Year:
Amount owed: $
Value:
Automobile #2: Model
Year:
Amount owed $
Value:
Other transportation (automobiles boats motorcycles Model) Model:
Year: Amount owed $:
Value: $
MONTHLY INCOME
Name of Employers
1.
2.
3.
Additional Income Description (not wages):
1 • monthly amount $
2. monthly amount $
Borrower Pay Days: Co- Borrower Pay Days
MONTHLY EXPENSES
(Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage $ Food $
2nd 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 Support/Alimony $ Spending Money $
Day /Child Care Tuition $ 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:
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 known regarding your lender's or lender loan
servicing company Lender 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 my 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
Gregory Javardian, Esquire, lender counsel:
Proof of income
Bank statements to cover the last 60 day period
If self employed, we must have the last 3 bank statements from both their business and personal
bank accounts.
Proof of any expected income for the last 45 days
Dodd Frank Certificate
4506T -EZ form
Copy of last two months utility bill
Letter explaining reason for delinquency and any supporting documentation
Hardship letter
Listing agreement if property is currently on the market
Gregory Javardian, Esquire
1310 Industrial Boulevard
2n Floor, Suite 202
Southampton, PA 18966
(tel) 215- 942 -9690
(fax) 215- 942 -9695
Attention: Jennifer McGarrity
(tel) 215- 942 -2090 ext. 1326
lennifer.mcgarrityna pkjllc com
����U��»� ����U��� ^�� ���U����U ���� ��o�����
~"" "~�"�"" " ~° OFFICE"~=~— �~" ~=~°"°"����"��'��"=�~ COUNTY
"
' RonnyRAnderson ^~F/G-E
Shorif �AOr� "
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Jody 8Smith `~ `" "8}� �U� � ! 8� |O` �n
Ch�/Dopu� ='°"°~ ' "'' '"' ��
Richard VVStewart CUMBERLAND COUNTY
Solicitor OF PENNSYLVANIA
James B. Nutter� Case Number
vu. |
2O13'4315
Jameson AWarren (et al.) |
SHERIFF'S RETURN OF SERVICE
07124/2013 O213PM' Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Jameson A Warren, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1
Adams Street, East Pennsboro, Enola, PA 17025. Residence is vacant and per the Enola Postmaster the
defendant moved and left no forwarding address.
07/24/2013 02:13 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Jennifer L Warren, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1
Adams Street, East Pennsboro, Enola, PA 17025. Residence is vacant and per the Enola Postmaster the
defendant moved and left nn forwarding address.
SHERIFF COST: $70.05 SO ANSWERS,
July 3O. 2O13 RONNYR ANDERSON, SHERIFF
wCountySuilo Sheriff,Telemoft,Inc.
FIL ED-OFFICE
POWERS, KIRN& JAVARDIAN, LLC f .6 THE PROTHONOTARY
GREGORY JAVARDIAN, ESQUIRE Id. No. 55669
MARY F. KENNEDY, ESQUIRE Id. No. 77149 2,0 13 AUG 29 AM 9: 14 4
MEGHAN K. BOYLE, ESQUIRE Id.No. 201661 CUMBERLAND COUNTY
SEAN P. MAYS, ESQUIRE Id No. 307518 PEW4SYLVANIA
RICHARD J. NALBANDIAN, III, ESQUIRE Id No. 312653
1310 INDUSTRIAL BOULEVARD
2nd FLOOR, SUITE 202
SOUTHAMPTON, PA 18966
"(215) 942-2090
James B.Nutter&Company COURT OF COMMON PLEAS
Plaintiff CIVIL,DIVISION
vs.
Jameson A. Warren and Jennifer L. Warren CUMBERLAND COUNTY
Defendants No. 13-4315 Civil
MOTION FOR ALTERNATIVE SERVICE PURSUANT
TO PENNSYLVANIA R.C.P. 430
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, by its attorney, Powers, Kim & Javardian, LLC and moves this
Honorable Court to Permit Plaintiff to obtain Alternative Service and seek an Order permitting service to be
effectuated upon the Defendants, Jameson A. Warren and Jennifer L. Warren, by posting a copy of the
Complaint and all subsequent pleadings upon the property located at 1 Adams Street,Enola,PA 17025-2802,
and by regular and certified mail pursuant to Pennsylvania Rule of Civil Procedure 430 and avers support
thereof:
1. Plaintiff filed a Civil Action Complaint against Defendants on July 23,2013.
2. The Defendants are the owners and mortgagors of the property 1 Adams Street,Enola,PA
17025-2802.
3. Plaintiff,James B.Nutter&Company, is the Mortgagee on said property.
4. Plaintiff has attempted to effectuate service of the Civil Action Complaint pursuant to
Pennsylvania Rule of Civil Procedure 402(a)upon the Defendants,Jameson A.Warren and
Jennifer L.Warren at the property known as 1 Adams Street,Enola,PA 17025-2802,which
was returned no service made. A true and correct copy of the Plaintiff's service is attached
and made apart hereof as Exhibit"A."
5. Pursuant to Pennsylvania Rule of Civil Procedure 430,Plaintiffhas made a good faith effort
to locate the Defendants including the following:
A. A process server contacted Directory Assistance and examined local internet
telephone directories, which indicated there is a listing for the Defendants at the
mortgaged premises.
B. Postmaster Letters have been forwarded to the Eneola Post office.
C. A process server examined the Credit Bureau and found mail is delivered to the
property, 1 Adams Street,Enola,PA 17025-2802.
} D. A process server examined PA Department of Transportation records and found the <
driver's licenses are issued to both Defendants at the property address.
E. All addresses given have been attempted for service of the Complaint in Mortgage
Foreclosure on Defendants.A true and correct copy of the Affidavit of Good Faith
Effort to Locate Defendant is attached and made apart hereof as Exhibit`B."
6. Pennsylvania Rule of Civil Procedure 430 permits service of process in Mortgage
Foreclosure Actions by regular and certified mail to Defendants'last known address.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court enter an Order permitting service
upon said Defendants, Jameson A. Warren and Jennifer L. Warren, by posting a copy of the Civil Action
Complaint and all subsequent pleadings on the property known as 1 Adams Street,Enola,PA 17025-2802,
and by regular and certified mail, return receipt requested.
POWERS, KIRN& JAVARDIAN, LLC
BY:
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id. No. 77149
ghan K. Boyle, Esquire Id. No. 201661
can P. Mays, Esquire Id. No. 307518
chard J. Nalbandian, III, Esquire Id. No. 312653
Attorneys for Plaintiff
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriffs efra �;`frR
0`0,
Jody S Smith r¢
Chief Deputy
Richard W Stewart
Solicitor OFF C6 OF r"E""ERIrP
James B. Nutter&Company
Case Number
vs.
Jameson A Warren (et al.) 2013-4315
SHERIFF'S RETURN OF SERVICE
07/24/2013 02:13 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Jameson A Warren, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 1
Adams Street, East Pennsboro, Enola, PA 17025. Residence is vacant and per the Enola Postmaster the
defendant moved and left no forwarding address.
07/24/2013 02:13 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Jennifer L Warren, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1
Adams Street, East Pennsboro, Enola, PA 17025. Residence is vacant and per the Enola Postmaster the
defendant moved and left no forwarding address.
SHERIFF COST: $70.95 SO ANSWERS,
July 30, 2013 RONNf R ANDERSON, SHERIFF
,;;? ountySullo Sheriff,Toieosoft,Iric.
EXHIBIT "B"
c
Confidential Plaintiff: JB Nutter&Company
li]vestigBtive County: Cumberland
Services, Inc. vs.
Term#: 2013-4315
Defendant: Jamlcson A.Warren&JVnnifec Warren
Locatea6lvw- Warren
Address Given: 1 Adams Street,East PeJnusboro,Roola,PA 17025
ATTENTION: Tiesha Hester
Powers,Kirn,&Javardian,LLC
1310 industrial Boulevard
Southampton, PA 19107
File#: 13-029$
AFFIDAVIT OF GOOD FAITH INVESTIGATION
LAST KNOWN ADDRESS
1 Adams Street, Enola, PA 17025
INQUIRY OF THE CREDIT BUREAU _
The credit bureau reports that the moat,current-address of the subject is 1 Adams Street, Enola, PA
17025.
INQUIRY OF THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
The Pennsylvania Department of Transportation-Division of Motor Vehicles reports driver's license
number 24666062 is issued to Jameson Andrew Warren of 1 Adams Street, Enola, PA 17025, The
subject's license is current and not due to expire until August 31, 2014_
INQUIRY OF U.S. POST OFFICE (FOIA)
A request has been forwarded to the Enola-Post Office. I will forward their response immediately upon
my receipt.
SEARCH OF LOCAL TELEPHONE DIRECTORIES& PHONE COMPANY OPERATOR CONTACT
The telephone company operator reports 717-728-2869 is issued to the subject at 1 Adams Street in
Enola, PA.
CONTACTS
Ms_Wagner of 5 advises she knows Jennifer Warren but would not provide any information regarding
their whereabouts.
Contact could not be made at 717-728-2569 (also indicated on credit header) as no answer had been
reached.
1 Cl:rt•J'IFY TJND1;R PENALTY OF PERJURY,TRATTHr 1+QREGOIN(; IS•I'IZ EAND('OlUtECT,TO'I'IfEBESrOP MY K-TOIV'J:.RT)(il-:. I
UNDERSTAND THAT FALSE STATEMENTS BE-RI; X j%,RE airlfni:/,,��FLJ J ECT 1 rHE PE•v41.1'1J:s RELAT7NCr l t)LZ:SN'URN
F.ALS 11�ICATION TO AU THORI'I'I ES.
AFFIAN'1:
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235 South 136 Street T 1 Br ORE ME
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Philadelpbia PA 19107 OF' ,2013 cpl„l�;aY.iY4--� r� i Al,et-N RiYLVAN[A
(215)546?400 " NOT-ARtALSEA!
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Mite of =nq%iry: OR/08%2013
Use-ID: DTAt,IE
Subject_ Trfot atian: game: �arr�c�, ;aTieso�
SSI:: 161-69-97-63
Current Addross: 1 adans 5T
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"11ARREN,JAt--SOn,A &INCR 09i18/9� FAD'1�/01/12 M-758
1,i±DijMS,ST,ENOLA,PA,1,C25,TAPE RL"•'D 1-0/07,,1'APG DLR ;8,•'-a212'0313
•19LEPHGNF. nUM3ER (717) 728-2869 C•7./':1
n12,R91:C,S EriD,R.0 T,OT 81,DII.1.SURG,PA,1't0'19,T.kPS RPTT, 08i3?,^_R DLL 04/,),1/20'0
TE:, ,P'ONE VUN_DGR (717) ?213-•4739. SPEC 10/02
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reps:IM" .eportegUlfaxcomiedaUgeiResponse.htrn S!9
PFNN6YLVH2Y1A -
BUREAU 01' DRIVER LICSNOING
BASIC DRIVER INFORMATION
AUG 12 2013
DRIVER LICENSS NO : 24666062
DRIVER: jAMESON AllDREW WARREN DATE OF BIRTH : AUG 30 1978
1 ADAMS STREET SEX MALE
BNOLA, PA 17025 RECORD TYPE : OUT OF STATE
COmmSRCIAL DRIVER LICENSE
DRIVER LICENSE (DL) ---------------- - - -- - ------ (CLICENSE -
• ------- -
LICENSE CLASS C CAL LICENSE CLASS
CDL LYCE,'N5E ISSUED
LICENSE ISSUE DATE: AUG 29 2010 CDL LICENSE ISMS:
LICENSE EXPIRES AUG 31 399 CDL EB�DORSEMENTS NONE
QRIG ISSUE DATE JAI 03 1985 CDL RESTRICTIONS NONE
MED RESTRICTIONS : 1 CDD LEARNER PERMITS:
LEARNP,R PMlITS CDL LICENSE STATUS
LICENSE STATUS
Sg ENDORSEMENT
--PROSATIODNARY.LICEN3F (pL) _,_._.
PL LICENSE CLASS
PL LICENSE ORIG IS$
PL LICENSE ISSUED
PL LICENSE EXPIRES -
pL LICENSE STATUS
OCCUPATIONAL'LIMITED LIGENSB (01111)
OLL LICENSE CLASS
OLL LICENSE ISSUED
OLL LICENSE EXPIRES
OLL LICENSE STAm'US
*** END OF RECORD
Jameson A Warren
1 Adams St Enoia, PA 17025-2802 No answer
Home (717) 728-2869
(indicated on credit header)
Michele L Kennedy
5 Adams St,Apt 2 Enola, PA 17025-2814 No longer in service
Moyne (717) 695-2197
Barbara A Wagner Ms.Wagner advises she knows Jennifer Warren
5 Adams St,Apt 7 Enola, PA 17025-2814 but would not provide any information
Home (717) 728-3551 regarding her whereabouts.
Erica Clarke
5 Adams St,Apt 8 Enola, PA 17025-2814 Automatic voice message system
Home (717) 525-$781
Darry Wilkins
5 Adams St: Apt 8 Enola, PA 17025-2814 No longer in service
Home (717) 728-3325
Elizabet Sullivan
6 Adams St Enola, PA 17025-2801 Automatic voice message system
Home (7 1 7) 695-7949
Confidential Plaintiff: JS Nutter&Company
Investigative County: Cumberland
Sertizces, Inc. �s-
Term U. 2013-4315
Defendant: Jalnest►n A. Warren,&Jennifer Warren
Locate: Jennifer Warren
Address Given: 1 Adams Street,East Pennsboro,Enola, PA 17025
ATTENTION. Ticshn Aester
Powers,Kirn,&Javardian,LLC
1310 Industrial Boulevard
Southampton,PA 19107
Tile#: 13-0298
AFFIDAVIT OF GOOD FAITH MSSTIGATION
LAST KNOWN ADDRESS
1 Adams Street, Enola, PA 17025
INQUIRY OF THE CREDIT BUREAU
The credit bureau reports that the most current address of the subject is 1 Adams Street, Enola, PA
17025,
INQUIRY OF THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
The Pennsylvania Department of Transportation—Division of Motor Vehicles reports driver's license
number 23463949 is issued to Jennifer L, Warren of 1 Adams Street, Enola, PA 17025. The subject's
license is current and not due to expire until November 19, 2014.
INQUIRY OF U-S. POST OFFICE (FOIA)
A request has been forwarded to the Enola Post Office. I will forward their response immediately upon
my receipt.
SEARCH OF LOCAL TELEPHONE DIRECTORIES& PHONE COMPANY OPERATOR CONTACT
The telephone company operator reports 717-728-2869 is issued to Jameson Warren at 1 Adams
Street in Enola, PA.
CONTACTS
Ms.Wagner of 5 advises she knows Jennifer Warren but would not provide any information regarding
their whereabouts.
Contact could not be matte at 717-728-2869(also indicated on Jameson Warren's credit header) as no
answer had been reached.
Contact could not be made at 717-728-4239(indicated on credit header) as the listing is not in service.
I CERTIFY C:N DFR PENALTY OF POCKTRY,THAT TIfE FOREGOING IS TRUE AND CORK CT,TO THE Bl;ti'r OF MY KN-0W1 :13trH_ T
UNDERSTAND THAT FALSE STATEMT-KI'S HLREIN ART;MADE SUBJECT T 7'r IH t'ENALTIES ItrI.A77ACi TO[NSV4'ORN
FALSITICAT[ON TO AUTHOR[TI F.:;.
AFFIANT: .p,r�'
ie4NE CO ' : .CLI
n
735 South 13th Street. swo T&S RS BEI)13EFORE ME'1 ca !n`r'r,:4at8�EVktictr
Philadelphia.PA 14107 U 2013 �IMAR;RLg
(2l 5)546-7400 r I' EftAR0eEf TSQN,.Nc-ISrYP bi
' l�Gf l�Yrid�lbfida.I�±ea,A ic
(800)503-7400 �� s�ty
Fax(215)985-0169 Nt R SL1C. - -- Sri- !s r 14 P014
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W13 Report Results-This Farm Produced byEquifax User Reference:DIANE
frigulry Informati=
Date of Inqui-y: OB/08/;ZO13
LT5erlDi C=AtbL
�';ua;ect _nforrnaLion: Name: wAr.lin, jennifar
9SA- _95-68-269.1
:,urront Address_ adans ST
encia, Fn 17025
ltaWW Results
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A' ADDRESS p:oC:REPANCY - NO SUBSTANTIAL rIFFERENCL'' 0CMYRRED
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ATLANTA,GA,30374-0210,8JC/6'85-11__,WO- ,E:).UIFAX.COM/FeR
xTJRRREN,JENNIFFR,LYNNE STNCE 06/18/93 FAD 07/:9/=3 FN-?42
a,ADA`iS,S':,ENOiA,PA,'1'7025,TAPE• RPTD 10/00,TAYE L'LR 08/'j5/2C13
'1''3LEPHOtiF. NUMBER {7i7t 728-42=19 SPEC 11/05
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F N-SV--TH.JENNT FE R,L
LIDS-11/12/1574,SS8-195-58-269'.
END OF REPORT EQU=SAX AND r.FFILIATES - 08 8,'13
https:lhnv►w.eporteq ulfaxcomledatlgelResponse.Fdm 1 f 1
BVREAU OF DRIVER LICENSING
BASIC DRIVER INFOMATION
AUG 12 2013
DRIVER: JENNIFER L WARREN DRIVER LICENSE NO 23463949
1 ADAMS ST DATE OF BIRTH : .NOV 16 1974
ENCLA, PA 17625 SEX : FFNALE
RECORD TYPE : 4YR LIC/LP
DRIVER LICENSE (DL) COMYRERCZAL DRIVER LICENSE (M)
LICENSE CLASS - . C --- --- CnL LICENSE CLASS
LIC,M4SE SSSU$ DhTE: NOV 23 2010 CDL LICENSE YBBUB'D :
LICENSE EXPIRES NOV 19 2014 CDL LICENSE EXPIRES:
ORIG ISSUE DATE MAR Ob 1991 CAI+ FUDORVEMBNTS NONE
MED RESTRICTIONS : NONE CDL RESTRICTIONS L
LEARNER PERMITS CDL LEARNER PER14TTS:
LICENSE STATUS CDL LICENSE STATUS :
SS E3DORSLMENT : NOT VALID
pROBATIONARY tICENSE (FL)
PL LICENSE CLASS
PL LICENSE ORIG ISS
PL LICENSE ISSUED
PL LICENSE EXYTRES
PL LIGHNSE STATUS
OCCUPATZOBTAL LIMITED LICENSE (OLL)
OLL LICENSE CLASS
OLL LIMSE ISSUED
OLL LICENSE EXPIRES
OLL LICENSE STATUS
*w END OF RECORD ***
Jameson A Warren
1 Adams St Ertola, PA 17025-2802 No answer
Horne (717) 728-2869
(indicated on credit header)
Michele L Kennedy
5 Adams St.Apt 2 Enola, PA 17025-2814 No longer in service
Horne (717)695-2197
Barbara A Wagner Ms,Wagner advises she knows Jennifer Warren
5 Adams St,Apt 7 Enola, PA 17025-2814 but would not provide any information
Nome (717) 728-3551 regarding her whereabouts.
Erica Clarke
5 Adams St: Apt 8 Enola, PA 17025-2814 Automatic voice message system
Dome (717) 525-8781
Darry Wilkins
5 Adams St.Apt 8 Enole, PA 17025-2814 No longer in service
Home (717) 728-3325
Eiizabet Sullivan
6 Adams St Enola, PA 17025-2801 Automatic voice message system
Home (717) 695-7949
Or .)-e.rtY"ti��Y"� i�J���r"1 CrL'-o��� i"��'��-�•
POWERS, KIRN & JAVARDIAN, LLC
GREGORY JAVARDIAN, ESQUIRE Id. No. 55669
MARY F. KENNEDY, ESQUIRE Id.No. 77149
MEGHAN K. BOYLE, ESQUIRE Id. No. 201661
SEAN P. MAYS, ESQUIRE Id No. 307518
RICHARD J.NALBANDIAN, III, ESQUIRE Id No. 312653
1310 INDUSTRIAL BOULEVARD
2nd FLOOR, SUITE 202
SOUTHAMPTON, PA 18966
(215) 942-2090
James B.Nutter&Company COURT OF COMMON PLEAS
Plaintiff CIVIL,DIVISION
VS.
Jameson A. Warren and Jennifer L. Warren CUMBERLAND COUNTY
.Defendant No. 13-4315 Civil
CERTIFICATE OF SERVICE
The undersigned,counsel for the Plaintiff,hereby certify that a copy of the Motion for Alternative
Service was served on the following persons by first class mail,postage prepaid,on the date indicated below.
Jameson A. Warren Jennifer L. Warren
1 Adams Street 1 Adams Street
Enola,PA 17025-2802 Enola,PA 17025-2802
Defendant Defendant
POWERS, KIRN&JAVARDIAN, LLC
DATE: l BY:
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id.No. 77149
Meghan K. Boyle, Esquire Id.No. 201661
Wan P. Mays, Esquire Id.No. 307518
'chard J. Nalbandian, III, Esquire Id.No. 312653
Attorneys for Plaintiff
y ..
POWERS, KIRN &JAVARDIAN, LLC
GREGORY JAVARDIAN, ESQUIRE Id. No. 55669
MARY F. KENNEDY, ESQUIRE Id.No. 77149
MEGHAN K. BOYLE, ESQUIRE Id. No. 201661
SEAN P. MAYS, ESQUIRE Id No. 307518
RICHARD J.NALBANDIAN, III, ESQUIRE Id No. 312653
1310 INDUSTRIAL BOULEVARD
2"d FLOOR, SUITE 202
SOUTHAMPTON, PA 18966
(215) 942-2090 ATTORNEYS FOR PLAINTIFF
James B.Nutter&Company COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
vs.
Jameson A. Warren and Jennifer L. Warren CUMBERLAND COUNTY
Defendants No. 13-4315 Civil
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR
ALTERNATIVE SERVICE PURSUANT
TO PENNSYLVANIA R.C.P. 430
Plaintiff, by its attorney,Powers,Kim&Javardian,LLC moves this Honorable Court to Permit
Plaintiff to obtain Alternative Service and seek an Order permitting service to be effectuated upon the
Defendants, Jameson A. Warren and Jennifer L. Warren,by posting a copy of the Complaint and all
subsequent pleadings upon the property located at 1 Adams Street,Enola,PA 17025-2802,and by
regular and certified mail pursuant to Pennsylvania Rule of Civil Procedure 430 .
Plaintiff filed a Complaint against Defendants on July 23, 2013. Plaintiff attempted to effectuate
service of the Complaint pursuant to Pennsylvania Rule of Civil Procedure 402(a)upon the Defendants,
Jameson A. Warren and Jennifer L. Warren at the property known as 1 Adams Street,Enola, PA
17025-2802. The Sheriffs Office has been unable to serve the Complaint on the Defendants. The Return
of Service indicates the Defendants were not found. There was no response. Several attempts were
made.
Pennsylvania Rule of Civil Procedure 430 permits service of process in this action by regular and
certified mail to the property address. Plaintiff respectfully requests that this Honorable Court enter an
Order permitting service upon said Defendants by posting on the property known as 1 Adams Street,Enola,
PA 17025-2802.
POWERS, KIRN & JAVARDIAN, LLC
BY: `��-----
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id. No. 77149
eghan K. Boyle, Esquire Id. No.,201661
can P. Mays, Esquire Id. No. 307518
Richard J.Nalbandian, III, Esquire Id.No. 312653
Attorneys for Plaintiff
' r
COURT OF COMMON PLEAS
CIVIL DIVISION
James B.Nutter&Company CUMBERLAND COUNTY
Plaintiff No. 13-4315 Civil
vs.
Jameson A. Warren and Jennifer L. Warren
Defendant
ORDER GRANTING ALTERNATIVE SERVICE PURSUANT
TO PENNSYLVANIA R.C.P. 430
This matter being opened to the Court by Plaintiff, upon Motion for Order Granting Alternative
Service,pursuant to Pennsylvania R.C.P.430,and the Court having reviewed and considered the pleadings
submitted in connection with this matter, and for good cause shown;
IT IS on this y day of 2013 , ORDERED that the Motion for
Alternative Service of the Complaint in Mortgage Foreclosure and all subsequent pleadings by posting the
premises 1 Adams Street,Enola,PA 17025-2802, and by regular and certified mail to the Defendant's last
known address, is hereby GRANTED.
BY THE URT:
J.
rTj Co
.x -0
CD
I t7rk k A�? �z�-ao
9lkl/2
#13-0298
POWERS,KIRN & JAVARDIAN5 LLC
By: Jill Manuel-Coughlin 2013 SEP 1
rn 3 + i ;
Attorney Id#63252
1310 Industrial Boulevard, 2nd Floor, Suite 202 U
Southampton, PA 18966 CMBERLAND
COUNTy
Telephone: 215-942-2090 PENNS YLVANIA
Aitomeys for Plaintiff
JAMES B.NUTTER&COMPANY COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
VS. CUMBERLAND COUNTY
JAMESON A.WARREN No. 13-4315 Civil
JENNIFER L. WARREN
Defendant(s)
PPJL-ECIEPE TO REINSTATE COMPLAINT
TO THE COURT:
Kindly Reinstate the Complaint in Mortgage Foreclosure for an Additional thirty (30)days.
Jill anuel-Coughlin
Attorney ID#63252
POWERS, KIRK & JAVARDIAN, LLC
Attorneys for Plaintiff
Dated: September 11, 2013
•#13-0298
POWERS,KIRN&JAVARDIAN,LLC
1310 Industrial Boulevard, 2nd Floor, Suite 202
Southampton,PA 18966
Telephone: 215-942-2090
Attorneys for Plaintiff
James B.Nutter&Company : COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff : CUMBERLAND COUNTY
vs.
c
No. 13-4315 Civil �
Jameson A. Warren M M
Jennifer L.Warrens
CD
Defendant(s)
AFFIDAVIT OF SERVICE �—� rya ° .
- 4
r�
I hereby certify that per the Court Order dated September 4,2013 copies of the reinstard
Complaint in Mortgage Foreclosure were sent to the Defendant(s)Jameson A. Warren&Jennifer L.
Warren at 1 Adams Street,Enola,PA 17025 by certified and regular mail,by first class United States
Mail, postage prepaid on September 17,2013 as evidenced by the attached.
This statement is subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated: September 17,2013
Jill rnie -Coughlin, squ re
Atto for Plaintiff
- -- —- ----- --- --
. . POTTED
p(FS POST i
Jian,LLC • , /
66d /�E�I PITNEY BOWES
1 02 1 P $ 006.270 i
0003194302 SEP. 17 2013
MAILED FROM ZIP CODE 18966
- - - --- 7196 9008 9040 2003 1405
RE•rURN RLScclP,r(ELLcrRONIC)
f iln]C5J11�'iiPi'G17
I Adams Streot
Etiola,PA 17025
Z �
ardian,LLC _ `� �
'PITNEY BOWES
lievard 02 1 P $ 001 -920
i
I
8966 +
! .� ;0003194302 SEP 17 2013
MAILED FROM ZIP CODE 1 8966
I„Il 1,nnlllll fl,,Illf,I„II„lililllllllllnlll�n{I�i41111111
Jameson Warren
1 Adams Street
Enola,PA 17025
o
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s
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;an,LLC - - �� 7 ``===z-,PffTWEYY BOWES
vard 02 1 P tiJ®V.27o
66 -:0003194302 SEP 172013
MAILED FROM ZIP CODE 1 8966
7196 9008 9040 2003 1481
ItfLTURN iti-i oi—iT(rLEC1'RONIC)
"i�l�l1II111��11,iIf Jyulla���l�ill(�,�i,ll,�"Il�llit�li���f
lcnniler 1„iti'�rr.�rt
1 .Adams Strcct
Enola,PA 170-ZS
A
1.
• i
E
1
j
' � f
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ...
�,,tv nt w:�tart0er,yr ; L� ill.:Ni
Jody S Smith '
Chief Deputy l3 SE? 27 AFB 10: 2 ,'
Richard W Stewart 1.71.1MBERLAND COlt m,
Solicitor p. . :r T .E� m,iF
PENNSYLVANIA
James B. Nutter&Company
vs. Case Number
Jameson A Warren (et al.) 2013-4315
SHERIFF'S RETURN OF SERVICE
09/20/2013 12:55 PM- Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Jameson A Warren, pursuant to Order of Court by"Posting"the premises
located at 1 Adams Street, East Pennsboro, Enola, PA 17025 with a true and correct copy according to
law.
/(
~r'
Alr
R r CLINE, DEPUTY
09/20/2013 12:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant,to wit: Jennifer L Warren, pursuant to Order of Court by"Posting"the premises
located at 1 Adams Street, East Pennsboro, Enola, PA 17025 with a true and correct copy according to
law.
/c.
IAM LINE, DEPUTY
SHERIFF COST: $72.95 SO ANSWERS,
if "K4.1
September 23, 2013 RONNY R ANDERSON, SHERIFF
u,, u snf 1,,,,s-c`• ;;.
POWERS, KIRN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id No. 307968
HARRY B. REESE, ESQUIRE Id No 310501
DANIEL C. FANASELLE, ESQUIRE Id No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549
1310 INDUSTRIAL BOULEVARD
2nd Floor, SUITE 202
SOUTHAMPTON, PA 18966
215-942-2090
James B. Nutter & Company
4153 Broadway
Kansas City, MO 64171
vs.
Jameson A. Warren
Jennifer L. Warren
1 Adams Street
Enola, PA 17025-2802
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 13-4315 Civil
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
2 pH 4:0
1,01,8R4
cfoisYN��/Jt��
Kindly enter judgment in favor of the Plaintiff and against Jameson A. Warren and Jennifer L. Warren,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for
foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows:
As Set forth in Complaint $79,332.04
Interest 07/11/2013 to 05/19/2014 4,635.53
TOTAL $83,967.57
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached.
Damages are hereby assessed as indicated.
DATE:
owers, Kirn & sociates, LLC
❑Jill Manuel -Coughlin, : squire Id. No. 63252
111J9lanta Pekalska, Esquire, Id. No. 307968
IR'narry B. Reese, Esquire, Id. No. 310501
❑Daniel C. Fanaselle, Esquire, Id. No. 312292
❑Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff
PROTHONOTARY
P
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
or at ellnibert
4;14
OF; ice OF ME SKERiF;
James B. Nutter & Company
vs.
Jameson A Warren (et at)
Case Number
2013-4315
SHERIFF'S RETURN OF SERVICE
09120/2013 12:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Jameson A Warren, pursuant to Order of Court by "Posting" the premises
located at 1 Adams Street, East Pennsboro, Enola, PA 17025 with a true and correct copy according to
law.
CLINE, DEPUTY
09/20/2013 12:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Jennifer L Warren, pursuant to Order of Court by "Posting" the premises
located at 1 Adams Street, East Pennsboro, Enola, PA 17025 with a true and corre copy according to
law.
AM INE, DEPUTY
SHERIFF COST: $72.95 SO ANSWERS,
September 23, 2013
(C) CounlySuito Shenft Teleosoft. Inc.
RONNY R ANDERSON, SHERIFF
#13-0298
POWERS, KIRN & JAVARDIAN, LLC
GREGORY JAVARD.IAN, ESQUIRE ID. NO. 55669
JILL MANUEI..-COUGI•LLIN, ESQUIRE ID. NO. 63252
MARY F. KENNEDY, ESQUIRE ID. NO. 77149
MEGHAN K. BOYLE, ESQUIRE ID. NO. 201661
SEAN P. 'MAYS, ESQUIRE ID. NO. 307518
DANIEL C. FANASELLE, ESQUIRE ID. NO. 312292
RICHARD J. NAI,BAN:DIAN, III :ESQUIRE ID. NO. 312653
1310 INDUSTRIAL, BOULEVARD
2`D FLOOR, SUITE 202
SOU'I'IIAMPTON, PA 18966
(215)942-2090
ATTORNEYS FOR. PLAINTIFF
JAMES 13. NUTTER & COMPANY
PLAINT' FP
VS.
JAMESON A. WARREN
JENNIFER L. WARREN
DEFENDANTS
Jameson A. Warren
1 Adams Street
.Enols. PA 17025-2802
DATE OF NOTICE: October J Y , 2013
IN TI'lE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 13-4315 CIVIL
Jennifer L. Warren
1 Adams Street
Enola, PA 17025-2802
NOTICE, RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed to take action required by you in this case. 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.
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013 -
Phone: 717-243-9400
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 170:13 -
Phone: 717-249-3166
Powers, Kim & Javardian, LLC
BY:�--A'
❑ Gregory Javardian, Esquire Id. No. 55669
o Jill Manuel -Coughlin, Esquire :Id. No. 63252
o Mary P. Kennedy, Esquire Id, No. 77149
❑ Meghan K. Boyle, Esquire Id. No. 201661
❑ Sean P. Mays, Esquire Id. No. 307518
,Daniel C. Fanasellc, Esquire Id. No. 312292
❑ Richard J. Nalbandian, Ill, Esquire 1d. No.
312653
listed se eneuentra en estado de rebeldia par no Naber tornado la accion requiida de su pane en este caso. Al no tomar la accion debida dentro de
un termino do diez (10) dins dc esta notification, el tribunal podra, sin necesidad de comparareccr listed en carte o escuchar prueba alguna,
dictar sentencia en su contra, listed puede perder bienes )' otros dereehos importunes. Debe Ilevar esta notification a un abogado
imniediatemente si listed no bene abocado, a Si no bene diner° suficicnte para tal servicio, vaya en persona a flame por telpfono a la olicina,
cuya direction Sc encuentra cscrita abajo para avcriguar donde sc puede conscgnir assistencia legal.
"NOTICE PURSUANT TO PAIR I)E0'I' COLLECTION PRACTICES ACT
1'1115 IS AN ATTEMPT t MPT TO COLLECT A DEllf AND ANN' INFORMATION 013 t AINED WILL 1313 USED FOR THAT PURPOSE"
POWERS, KIRN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id No. 307968
HARRY B. REESE, ESQUIRE Id No 310501.
DANIEL C. FANASELLE, ESQUIRE Id No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549
1310 INDUSTRIAL BOULEVARD
2nd Floor, SUITE 202
SOUTHAMPTON, PA 18966
215-942-2090
James B. Nutter & Company
vs.
Jameson A. Warren
Jennifer L. Warren
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 13-4315 Civil
VERIFICATION OF NON-MILITARY SERVICE
Jill Manuel -Coughlin, Esquire, hereby verifies that he/she is attorney for the Plaintiff in the
above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit:
(a) Defendant(s), Jameson A. Warren and Jennifer L. Warren, is/are not in the Military or Naval
Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief
Act, 50 U.S.C.S. Appx. §§ 501 et. seq.
(b) Defendant, Jameson A. Warren, is over 18 years of age, and resides at 1 Adams Street,
Enola, PA 17025-2802.
(c) Defendant, Jennifer L. Warren, is over 18 years of age, and resides at 1 Adams Street, Enola,
PA 17025-2802.
(d) Plaintiff, James B. Nutter & Company, is an institution conducting business under the Laws
of the Commonwealth of Pennsylvania with an address of 4153 Broadway, Kansas City, MO 64171.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
s, Kim : Ass", tes, LLC
❑Jill Manuel -Coughlin, Esquire Id. No. 63252
❑J• anta Pekalska, Esquire, Id. No. 307968
any B. Reese, Esquire, Id. No. 310501
❑ Daniel C. Fanaselle, Esquire, Id. No. 312292
❑ Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff
v
Department of Defense Manpower Data Center
Results as of : May -27-2014 11:04:00 AM
SCRA 3.0
Status Report
Pursuant to SeYv cenembers Civil Relief Act
Last Name: WARREN
First Name: JAMESON
Middle Name: A
Active Duty Status As Of: May -27-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA" ' .
., No t_
NA
i
This response reflects the individuals' active duty status based on the Active Duty Status Date
•
t l
_. '1 I
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA - . c c 1 L
.. .-- No t I
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or Hls/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 '`. ..
r No f
NA
This response reflects whether the Iridtdual or his/her unit has received early notification to report for active duty
\ .
Upon searching the data banks of the Department of Defense Manpower. Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Y�.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
0 •
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOM Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 0AG99981Z02C340
,b
Department of Defense Manpower Data Center
Results as of : May -27-2014 11:05:43 AM
SCRA 3.0
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: WARREN
First Name: JENNIFER
Middle Name: L
Active Duty Status As Of: May -27-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA+ „
't No \
NA
This response reflects the Individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Das of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA -
-,. No I t
NA
This response
reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA .. - .
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (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: 7A126921B02DF90
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JAMES B. NUTTER & COMPANY COURT OF COMMON PLEAS
4153 BROADWAY
KANSAS CITY, MO 64171 CUMBERLAND COUNTY
vs. No.: 13-4315 CIVIL
JAMESON A. WARREN
JENNIFER L. WARREN
1 ADAMS STREET
ENOLA, PA 170025
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Amount Due
$83,967.57
Interest from 05/20/2014 to Date of Sale
@ $13.80 per diem $ 2,718.60_
Subtotal
(Costs to be added)
CD.
$028.00 PA «rN
105.(16 CBF
7.05 u
X03.75 "
II.75 "
10.50 "
304•yo_-POArN
4a.as .Co
50U
Q13i001
So99c251
N
Powers, Kirn & Associates, LLC
❑Jill Manuel -Coughlin, Esquire ld. No. 63252
❑Jolanta Pekalska, Esquire, Id. No. 307968
❑Harry B. Reese, Esquire, Id. No. 310501
gpaniel C. Fanaselle, Esquire, Id. No. 312292
ElMatthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff
1310 Industrial Boulevard
2nd Floor, Suite 201
Southampton, PA 18966
(215) 942-2090
JAMES B. NUTTER & COMPANY
vs.
JAMESON A. WARREN
JENNIFER L. WARREN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 13-4315 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
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 1 ADAMS STREET,
ENOLA, PA 17025:
1. Name and address of Owner(s) or reputed Owner(s):
JAMESON A. WARREN
1 ADAMS STREET
ENOLA, PA 17025
2. Name and address of Defendant(s) in the judgment:
JAMESON A. WARREN
JENNIFER L. WARREN
1 ADAMS STREET
ENOLA, PA 170025
1 ADAMS STREET
ENOLA, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
TOWNSHIP OF EAST PENNSBORO
98 SOUTH ENOLA DRIVE
ENOLA, PA 17025
1
4. Name and address of last recorded holder of every mortgage of record:
Plaintiff
5. Name and address of every other person who has any record lien on the property:
None.
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
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 North Hanover Street
P.O. Box 320
Carlisle, PA 17013
1 Courthouse Square
Old Courthouse, Room 106
Carlisle, PA 17013
Health and Welfare Building — Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenants/Occupants 1 ADAMS STREET
ENOLA, PA 17025
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
August 5, 2014
Powers, Kirn & Associates, LLC
❑Jill Manuel -Coughlin, Esquire Id. No. 63252
❑Jolanta Pekalska, Esquire, Id. No. 307968
❑Harry B. Reese, Esquire, Id. No. 310501
Daniel C. Fanaselle, Esquire, Id. No. 312292
❑Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff
POWERS, KIRN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id No. 307968
HARRY B. REESE, ESQUIRE Id No 310501
DANIEL C. FANASELLE, ESQUIRE Id No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549
1310 INDUSTRIAL BOULEVARD
2nd Floor, SUITE 202
SOUTHAMPTON, PA 18966
215-942-2090
JAMES B. NUTTER & COMPANY
vs.
JAMESON A. WARREN
JENNIFER L. WARREN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 13-4315
n
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JAMESON A. WARREN
JENNIFER L. WARREN
1 ADAMS STREET
ENOLA, PA 170025
i
La
Your house (real estate) at 1 ADAMS STREET, ENOLA, PA 17025, is scheduled to be sold
at Sheriffs Sale on DECEMBER 03, 2014 at 10:00 A.M., in the Cumberland County Courthouse,
One Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,967.57, obtained
by JAMES B. NUTTER & COMPANY, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215)
942-2090.
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 also be able to stop the sale through other legal proceedings.
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 on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (215) 942-2090.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened, you may call Powers, Kirn & Associates, LLC at (215) 942-2090.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state
who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within
ten (10) days.
7. You may also have other rights and defenses, or ways of getting your home 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 BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE IMPROVEMENTS
THEREON ERECTED SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, COUNTY OF
CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED
IN ACCORDANCE WITH A SURVEY AND PLAN THEREOF MADE BY ERNEST J.
WALKER, PROFESSIOINAL ENGINEER, DATED SEPTEMBER 2, 1970, AS FOLLOWS:
BEGINNING AT A POINT ON THE NORTHERLY SIDE OF ADAMS STREET, BEING 214
FEET IN A WESTWARDLY DIRECTION BY SAME FROM THE CENTER LINE OF SOUTH
ENOLA DRINE AS LAID OUT ON A PLAN OF LOTS OF JOHN Q. ADAMS AND JOSEPH
PYNE, RECORDED IN THE RECORDER OF DEEDS OFFICE, CUMBERLAND COUNTY, IN
PLAN BOOK 1, PAGE 17, THENCE SOUTH 78 DEGREES 30 MINUTES WEST ALONG THE
LINE OF SAID LAST MENTIONED LOT 150 FEET TO MONROE STREET, THENCE NORTH
78 DEGREES 30 MINUTES EAST ALONG MONROE STREET, 50 FEET TO A 15 FOOT
ALLEY, THENCE SOUTH 11 DEGREES 30 MINUTES EAST ALONG SAID ALLEY, 150 FEET
TO THE PLACE OF BEGINNING.
BEING THE SAME PREMISES which ROBERT A. AMATO AND MICHELE K. AMATO,
HUSBAND AND WIFE , by Deed dated 08/15/2000 and recorded 08/16/2000 in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book Volume 227, Page 391, granted and
conveyed unto JAMESON A. WARREN and JENNIFER L. WARREN.
BEING KNOWN AS: 1 ADAMS STREET, ENOLA, PA 17025
PARCEL #09-15-1291-299
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suitel00 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
JAMES B. NUTTER & COMPANY
4153 Broadway
Kansas City, MO 64171
Vs. NO 13-4315 Civil Term
CIVIL ACTION — LAW
JAMESON A. WARREN
JENNIFER L. WARREN
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $83,967.57
Interest from 5/20/14 to Date of Sale @ $13.80 --
Atty's Comm:
Atty Paid: $304.40
Plaintiff Paid:
Date: 8/15/14
L.L.: $.50
$2,718.60
Due Prothy: $2.25
Other Costs:
ary
(Seal) By:
REQUESTING PARTY:
Name: DANIEL C. FANASELLE, ESQUIRE
Address: POWERS, KIRN & ASSOCIATES, LLC
1310 INBDUSTRIAL BOULEVARD
2ND FLOOR, SUITE 201
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-2090
Supreme Court ID No. 312292
of
Da Proth
Deputy
POWERS, KIRN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id No. 307968
HARRY B. REESE, ESQUIRE Id No 310501
DANIEL C. FANASELLE, ESQUIRE Id No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549
EIGHT NESHAMINY INTERPLEX, SUITE 215
TREVOSE, PA 19053
215-942-2090
JAMES B. NUTTER & COMPANY COURT OF COMMON PLEAS
vs. CUMBERLAND COUNTY
JAMESON A. WARREN No.: 13-4315 CIVIL
JENNIFER L. WARREN
NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE
The Sheriff's Sale scheduled for December 3, 2014 at 10 A.M. in the above -captioned matter
has been continued until March 4, 2015 at 10 A.M.
Date: t2-2 t 1
wers, Kirn & Associa : , LLC
❑Jill anuel-Cough Esquire Id. No. 63252
❑Jo nta Pekals squire, Id. No. 307968
arry B. Reese, Esquire, Id. No. 310501
❑Daniel C. Fanaselle, Esquire, Id. No. 312292
❑Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff