HomeMy WebLinkAbout13-4651 Supreme Court,of'Pennsylvania
Court/,"" M C0 , Tleas
For Prothonotary Use Only:
�ivCoveE heet
CUIE � '3 County Docket No: `�� f
N 13
,%,70
The information collected on this form is used solely for court administration purposes. This form does tzot
supplement or replace thefiling and service of leadin s or other papers as required by lmv or rules of court.
Commencement of Action:
❑x Complaint ❑Writ of Summons ❑Petition
❑Transfer from Another Jurisdiction ❑Declaration of Taking
S Lead Plaintiffs Name: JPMORGAN CHASE BANK, Lead Defendant's Name: RICHARD K.GAVER
NATIONAL ASSOCIATION,SUCCESSOR IN
B+ INTEREST BY PURCHASE FROM THE FEDERAL
C DEPOSIT INSURANCE CORPORATION AS RECEIVER
OF WASHINGTON MUTUAL BANK F/WA
T
WASHINGTON MUTUAL BANK,FA SUCCESSOR IN
I INTEREST TO WASHINGTON MUTUAL HOME
O LOANS,INC.SUCCESSOR BY MERGER TO FLEET
N MORTGAGE CORP.
Dollar Amount Requested: ❑within arbitration limits
Are money damages requested? ❑Yes 0 No
(Check one) x❑outside arbitration limits
A Is this a Class Action Suit? ❑Yes 9 No Is this an MDJ Appeal? ❑ Yes No
Name of Plaintiff/Appellant's Attorney: Melissa J.Cantwell,Esq.,Id.No.308912,Phelan Hallinan,LLP
❑ Check here if you have no attorney (are a Self-Represented [Pro Se] Litigant)
Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑Intentional ❑Buyer Plaintiff Administrative Agencies
❑Malicious Prosecution ❑Debt Collection:Credit Card ❑Board of Assessment
❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections
❑Nuisance ❑Dept.of Transportation
S ❑Premises Liability ❑Statutory Appeal:Other
E ❑Product Liability(does not
include mass tort) ❑Employment Dispute:
C ❑Slander/Libel/Defamation Discrimination
T ❑Other: ❑Employment Dispute:Other ❑Zoning Board
I ❑Other:
0
N _ ❑Other:
MASS TORT
❑Asbestos
B ❑Tobacco
❑Toxic Tort-DES REAL PROPERTY MISCELLANEOUS
❑Toxic Tort-Implant ❑Ejectment ❑Common Law/Statutory Arbitration
❑Toxic Waste ❑Eminent Domain/Condemnation ❑Declaratory Judgment
❑Other: ❑Ground Rent ❑Mandamus
❑Landlord/Tenant Dispute ❑Non-Domestic Relations
®Mortgage Foreclosure: Residential Restraining Order
❑Mortgage Foreclosure:Commercial ❑Quo Warranto
❑Partition ❑Replevin
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages,you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so,the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A.LAWYER, 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 ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717)249-3166
(800)990-9108
File#: 820354
C"� � •r�
M Fri.
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ice.
PHELAN HALLINAN,LLP
Melissa J.Cantwell,Esq.,Id.No.308912
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza ATTORNEY FOR PLAINTIFF
Philadelphia,PA 19103
Melissa.Cantwell@phelanhallinan.com
215-563-7000
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, SUCCESSOR IN INTEREST BY COURT OF COMMON PLEAS
PURCHASE FROM THE FEDERAL DEPOSIT
INSURANCE CORPORATION AS RECEIVER OF CIVIL DIVISION
WASHINGTON MUTUAL BANK F/K/A
WASHINGTON MUTUAL BANK, FA SUCCESSOR TERM
IN INTEREST TO WASHINGTON MUTUAL HOME
LOANS, INC. SUCCESSOR BY MERGER TO FLEET NO. /'3
MORTGAGE CORP.
1111 POLARIS PARKWAY CUMBERLAND COUNTY
COLUMBUS, OH 43240
Plaintiff
V.
RICHARD K. GAVER
34 LYNBROOK LANE
DOYLESTOWN,PA 18901-2816
Defendant
CIVIL ACTION-LAW
COMPLAINT IN MORTGAGE FORECLOSURE S
Ts
File#: 820354
1. Plaintiff is
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR IN
INTEREST BY PURCHASE FROM THE FEDERAL DEPOSIT INSURANCE
CORPORATION AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A
WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO
WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO
FLEET MORTGAGE CORP.
1111 POLARIS PARKWAY
COLUMBUS, OH 43240
2. The name(s) and last known address(es) of the Defendant(s) are:
RICHARD K. GAVER
34 LYNBROOK LANE
DOYLESTOWN,PA 18901-2816
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 04/26/1993 RICHARD K. GAVER made, executed and delivered a mortgage upon
the premises hereinafter described to MELLON BANK, N.A. , which mortgage is
recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage
Book 1130, Page 466. By Assignment of Mortgage recorded 06/18/1996 the mortgage
was assigned to FLEET REAL ESTATE FUNDING CORP, A SOUTH CAROLINA
CORPORATION., which Assignment is recorded in Assignment of Mortgage Book 522,
Page 755.The mortgage and assignment(s), if any, are matters of public record and are
incorporated herein by reference in accordance with Pa:R.C.P. 1019(g); which Rule
relieves the Plaintiff from its obligations to attach documents to pleadings if those
documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
i
mortgage due 03/01/2013 and each month thereafter are due and unpaid, and by the terms
File#: 820354
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
by written notice sent to Mortgagor,the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage as of 07/08/2013:
Principal Balance $32,372.82
Interest from $961.05
02/01/2013 through 06/30/2013
Late Charges $74.40
Property Inspections $28.00
Subtotal $33,436.27
Escrow Balance 496.50
TOTAL $32,939.77
7. Plaintiff is not seeking a judgment of personal liability(or an in personam.judgment)
against the Defendant(s)in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s)has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy,but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in
2008, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as
provided by said notice has terminated because Defendant(s)has/have failed to meet with
the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied
assistance by the Pennsylvania Housing Finance Agency.
File 4: 820354
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$32,939.77, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN, LLP
By.
Melissa J. Cantwell, sq., d. No.308912
Attorney for Plaintiff
File#: 820354
LEGAL DESCRIPTION
ALL that certain parcel of half lot of land situate on south Prince Street, Borough of
Shippensburg, Cumberland County, Pennsylvania, more fully bounded and described as follows:
ON the South by lot of ground now or formerly of Anson Goodhart; on the West by an alley; on
the North by property now or formerly of J. Robert Snyder; and on the East by South Prince
Street. BEING the Southern one-half of Lot No. 223 in the Plan of the Borough of Shippensburg
and containing a frontage on South Prince Street of 32 feet, 2 inches, and extending in depth to
an alley on the West, a distance of 256 feet, 4 inches, and having thereon erected a frame
dwelling house,known and numbered as 18 South Prince Street.
BEING the same real estate which Michael H. Fabrizio and Deborah A. Fabrizio, husband and
wife,by their deed dated the 26th day of April, 1993, and intended to be recorded herewith in the
Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, conveyed to
Richard K. Gaver, the Mortgagor herein.
PROPERTY ADDRESS: 18 SOUTH PRINCE STREET,SHIPPENSBURG,PA 17257-
1920
PARCEL#33-34-2415-116.
File#: 820354
Pennsylvania Verification
STEFAN HEARST , hereby states tha he he is Vice President of
JPMorgan Chase Bank,N.A.the Plaintiff
in this matter, and is authorized to make this Verification. The statements of fact
contained in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of my information, and belief. I understand that this statement
is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
STEFAN HEARST
Vice President
Date: 07/26/13
JPMorgan Chase Bank,N.A
Borrower: RICHARD GAVER
Property Address: 18 SOUTH PRINCE STREET, SHIPPENSBURG, PA 17257
County: CUMBERLAND
Last Four of Loan Number:0600
`.. 'PROFESSIONAL ❑Quiet Title ❑ Other:
LIABILITY ❑Other: _
❑Dental
❑Legal _
❑Medical.
❑Other Professional:
Pa.R.C.P. 205.5 Updated 01/01/2011
FORM 1
IN THE COURT OF COMMON PLEAS
JPMORGAN CHASE BANK,NATIONAL OF CUMBERLAND COUNTY,PENNSYLVANIA
ASSOCIATION, SUCCESSOR IN INTEREST BY
PURCHASE FROM THE FEDERAL DEPOSIT
INSURANCE CORPORATION AS RECEIVER '
OF WASHINGTON.MUTUAL BANK F/K/A ca ,
WASHINGTON MUTUAL BANK,FA �--
SUCCESSOR IN INTEREST TO WASHINGTON cn r—
MUTUAL HOME LOANS, INC.SUCCESSOR BY -<D> r
MERGER TO FLEET MORTGAGE CORP. c
Plaintiff(s)
VS.
��
--� C)
RICHARD K.GAYER Defendant(s) (3-'(Ay i Civil r en
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 ate 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.
---F,irst wJthrn_tw.enty-(20)_days-ef y-our-receipt-of_this-.notice,you-must-contact MidP-enn-Legal-Ser-vicesat-(74-7)243-9400------
extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative,you must promptly meet with that legal representative within
twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and a
Request for Conciliation Conference with the Court,whichmust 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 towork out reasonable arrangements with your
tender 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 law}er complete a.financial worksheet in the format attached
hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed
within sixty(60)days of the service upon you of the foreclosure complaint. If youdo 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
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE,YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
3
Date Melissa J.Cantwell,Esq.,Id.No.308912
Attorney for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
Borrower name(s):
Property Address:
City: __- State: Zip:
Is the property for sale? YesEl No 0 Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes Q No .❑
Mailing Address(if different):
City: State: Zip•
Phone Numbers: Home: Office:
Cell. Other:
Email:
#of people in household: How long?
Mailing Address:
City: State: Zip
Phone Numbers: Home, . Office:
Cell: Other:
Email:
#of people in household: How long?
I FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes&Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes❑ No ❑
If yes,provide names, location of court, case number&attorney:.
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ — $
Retirement Funds: $— $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile 41:Model; _ Year:
Amount owed: Value:.
Automobile#2: Model: Year:
Amount owed: Value:
Other transportation(automobiles, boats,motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1. Monthly Gross _ Monthly NetT _
2. Monthly Gross Monthly Net
3, Monthly Gross Monthly Net
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 �. ...
2° Morte Utilities
Car Payment(s) Condo/Nei li. Fees
Auto Insurance Med. (not covered)
- Auto fuel/repairs Other ro a ment
ent Cable TV
Install.Loan Palm— _........-__..........-----. _ ___....._--._ _..�...__
Child Support/Alim. � S ending Money
Day/Child Care/Tuit. 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.infonnation:
Counseling Agency: Counselor:
Phone(Office):
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)
assistance?
Yes❑ No F-1
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 F-1 No❑
If yes,please indicate the status of those negotiations:
Please provide the following information, if known,regarding your lender and lender's loan servicing
company:
Lender's Contact{Name):_ Phone:
Servicing Company(Name):
Contact:
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 counseling services provided by the above named
-B6ri6;v6f Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information,to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement(if property is currently on the market)
` i
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
,,vo of Clone(I J f :rf
Jody S Smith
Deputy C.! i OC - 6 � �}.; -
Richard W Stewart I
Solicitor I �Ct��.�;r` 7 � ', t
JPMorgan Chase Bank, NA
vs. Case Number
Richard K. Gayer 2013-4651
SHERIFF'S RETURN OF SERVICE
08/15/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Richard K. Gayer, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Bucks, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
08/22/2013 03:48 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage F. losure by handing
a true copy to a person representing themselves to be Michael Keith, Ad- • .ant, ho accepted as
"Adult Person in Charge"for Richard K. Gayer at 18 South Prince Ste:. / .. -nsburt Borough,
Shippensburg, PA 17257.
ty.
SH "TIT HAR'■N, DEPUTY
09/23/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Bucks County, the within named Defendant Richard K.
Gayer, not found. Edward Donnelly, Sheriff, Return of Service attached to and made part of the within
record.
SHERIFF COST: $75.60 SO ANSWERS,
September 23, 2013 RONNR ANDERSON, SHERIFF
rnfi- 6v-f. Ott;
i
' BUCKS COUNTY '\ OC
SHERIFF'S RETURN 1 1 of 1
Bucks County Case# 2013321 19 Filed 8/8/2013 in CUMBERLAND COUNTY
Bucks Case# 2013321 19 Rec'd 9/3/2013
Invoice to be mailed to Special Instructions
County Sheriffs Office
I
Attn:
Action Civil Action COMPLAINT
Plaintiff JPMORGAN CHASE BANK
-VS-
Defendant RICHARD K GAVER
37 LYNBROOK LANE
DOYLESTOWN, PA 18901
Address Served if Different
MELISSA J CANTWELL,ESQ
i
Special Instructions Served under Pa. R.C.P.#402
(A)(i)Defendant personally served
(A)(2)(i)Family Member
(A)(2)(i)Adult in Charge of Residence
(A)(2)(ii)Manager/Clerk at Deft's Lodging
(A)(2)(iii)Person in Charge of Business
By Handling to
By Posting
o "erv•d
0 Days Ran Out Defendant Not Home
Defendant Moved Address Vacant
Defendant Unknown Deputy needs better address
Checked Post Office No Forwarding
Forwarding Address
Notes By Deputy .0 A_ /
Witness
At C C7 o'clock 'M)on % '/3
The above document was served/not served on the defendant as per
information list 3';ove - Co nt of Bucks,Commonwealth of
Pennsylvania 1/ O
�_ fir. ,.,��
So answers: �.�. .�•, -.
/ /eriff of BuctWounty
Affirmed and scribed before mein his day 0 9 / 13 /.20/3
\I-cy)a6 Prothontary �L
Affirmed and subscribed before me on this day / /
/ g 7j Iv 6 .-2 , 7t/.7 /l,7 k, Notary Public
�/ My Corn.Exp.
-_72 I�/1._ 9k 7k/ / n,21/a
.7(/ ±7f// 741/7", C.LJ 0///1/ ZONE 7
//ut u-1 /c'% �(/ _ al + 7 /
i �LEO'OPEf '.
y THE PROTHONOTARr
7614 JAN 24 AM W. 42
PHELAN HALLINAN,LLP
Emily M.Phelan,Esq.,Id.No.315250 CUMBERLAND COUNTY
1617 JFK Boulevard,Suite 1400 PENNSYLVANIA
One Penn Center Plaza
Philadelphia,PA 19103
emily.phelan@phelanhallinan.com
215-563-7000
JPMORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS
ASSOCIATION, SUCCESSOR IN INTEREST
BY PURCHASE FROM THE FEDERAL CIVIL DIVISION
DEPOSIT INSURANCE CORPORATION AS
RECEIVER OF WASHINGTON MUTUAL CUMBERLAND COUNTY
BANK F/K/A WASHINGTON MUTUAL
BANK, FA SUCCESSOR IN INTEREST TO
WASHINGTON MUTUAL HOME LOANS,
INC. SUCCESSOR BY MERGER TO FLEET
MORTGAGE CORP.
Plaintiff
vs.
RICHARD K. GAVER No. 13-4651-CIVIL TERM
Defendants
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
PHELAN LINAN, LLP
By:
Emily M. Phelan,Esq., Id. No.315250
Attorney for Plaintiff
Date: !/ ( `
L''/
/nru, Svc Dept. /� 7
File#820354
z 3�
A 3 S
Ronny R Anderson
Sheriff
Jody S Smith
Chief Depu
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF =UMBER A
N�'~ 0]F /[o
THE PRO7HOt/ti
l
"R\
7014MAR 12 PH 2: 1 /
CUMBERLAND COUNTY
tYr=F CE OF THE SHERIFF=
JPMorgan Chase Bank, NA
vs.
Richard K. Gayer
Case Number
2013-4651
SHERIFF'S RETURN OF SERVICE
01/27/2014 Sheriff Ronny R Anderson, being duly sworn according to !em, states he made diligent search and inquiry
for the within named Defendant to wit: Richard K. Gayer, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Bucks, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
01/31/2014 12:56 PM - Deputy Tim B|eck, being duly sworn accordin to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Blaine Redden, who accepted as "Adult Person in
Charge" for Occupant at 18 South Prince Street, Shippensburg Bovough, Shippeneburg, PA 17257.
�� T|K88LAC .OEpUTy
02/10/2014 The requested Notice of Residential M Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure served by the Sheriff of Bucks County upon Valdona Gayer, who accepted for
Richard K. Gayer, at 34 Lynbrook Lane, Doylestown, PA 18901-2816. Edward Donnelly, Sheriff, Return of
Service attached to and made part of the within record.
SHERIFF COST: $60.80 SO ANSWERS,
February 28, 2014 RONNPyR ANDERSON, SHERIFF
Bucks County Case # 201430200
Invoice to be mailed to
County Sheriffs Office
Attn:
PHELAN HALLINAN
Special Instructions
Notes
ILI-6 -6318
BUCKS COUNTY OC
SHERIFF'S RETURN 1 of I
Filed 1 /22/2014 in CUMBERLAND COUNTY
Bucks Case # 201430200 Rec'd 2/4/2014
Special Instructions
Action Civil Action COMPLAINT
Plaintiff JPMORGAN CHASE BANK
- VS -
Defendant RICHARD K GAVER
34 LYNBROOK LANE
DOYLESTOWN, PA 18901
Address Served if Different
ervednder Pa. R.C.P. #402
(A) (i) Defendant personally served
(A) (2) (i) Family Member
(A) (2) (i) Adult in Charge of Residence
(A) (2) (ii) Manager /Clerk at Deft's Lodging
(A) (2) (iii) Person in Charge of Business
By Handling to GLtc-1 61' 'x.. 4_- .1�
By Posting
Named
30 Days Ran Out
Defendant Moved
Defendant Unknown
Checked Post Office
Forwarding Address
Defendant Not Home
Address Vacant
Deputy needs better address
No Forwarding
By Deputy ,_,i preset? „yt
Witness
At /J / o'clock (AM ) on
The above document
information listed
Pennsylvania.
So answers:
•
ve
Affirmed and Subscribed befor,
Prothontary
Affirmed and subscribed before
of
d on the defendant as per
Buc , ommonwealth of
407
eriff of Buc
unty
on this day 002 / •/ /020/(1
/e on this day / /
Notary Public
My Corn. Exp.
/ /tJ
.2/.2-e)
ZONE 7
SH0201
DATE: 02/20/2014
TIME: 19:35
SHERIFFS OFFICE - EDWARD J. DONNELLY, SHERIFF
ADMINISTRATION BUILDING
DOYLESTOWN, PA 18901
BUCKS MISC DOCKET # 2014 30200 LOCATION: OUT OF COUNTY CLASS: ASSUMPSIT
* * * ** SHERIFF'S RETURN OF SERVICE * * * **
SHERIFF'S OFFICE
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE, RM 303
CARLISLE PA 17013
ATTN:. PHELAN HALLINAN
PLAINTIFF DEFENDANT
JPMORGAN CHASE BANK VS. GAVER
34 LYNBROOK LANE
DOYLESTOWN, PA
RICHARD K
18901
01222014 COMPLAINT - CIVIL ACTION RECEIVED FROM CUMBERLAND COUNTY NJC
PHELAN HALLINAN
02042014 RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TRANSACTION # 14 1 01929 NJC
AMOUNT PAID $ 58.00
02102014 SHERIFF'S RETURN, UNDER OATH, FILED. DEPUTY LIVERMAN AT 10:31 NJC
SERVED DEFENDANT, RICHARD K GAYER, PURSUANT TO PA.R.C.P. #402(A)(2)(
I)BY HANDLING TO VALDONA GAYER, WIFE, AT 31 LYNBROOK LANE, DOYLESTOW NJC
N, PA.
02202014 INVOICE MAILED TO CUMBERLAND COUNTY NJC
PHELAN HALLINAN LLP
END OF CASE
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
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CUMBERLAND
PENSYLVANI COUNT?'
Attorney For Plaintiff
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,
SUCCESSOR IN INTEREST BY PURCHASE FROM THE
FEDERAL DEPOSIT INSURANCE CORPORATION AS
RECEIVER OF WASHINGTON MUTUAL BANK F/K/A
WASHINGTON MUTUAL BANK, FA SUCCESSOR IN
INTEREST TO WASHINGTON MUTUAL HOME LOANS,
INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE
CORP.
Plaintiff
v.
RICHARD K. GAVER
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13 -4651 -CIVIL TERM
PRAECIPE
TO THE PROTHONOTARY:
® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑ Please mark the above referenced case Settled, Discontinued and Ended.
n Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
n Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
❑ Please a, ate the Judgment entered.
Date:
PH # 820354
By
:rushwood, Esq., Id. No.310592
Attorney for Plaintiff
HALLINAN, LLP
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,
SUCCESSOR IN INTEREST BY PURCHASE FROM THE
FEDERAL DEPOSIT INSURANCE CORPORATION AS
RECEIVER OF WASHINGTON MUTUAL BANK F/K/A
WASHINGTON MUTUAL BANK, FA SUCCESSOR IN
INTEREST TO WASHINGTON MUTUAL HOME LOANS,
INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE
CORP.
Plaintiff
v.
RICHARD K. GAYER
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13 -4651 -CIVIL TERM
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular
mail to the person(s) on the date listed below:
RICHARD K. GAYER
34 LYNBROOK LANE
DOYLESTO 1 , PA 18901-2816
Date:
LLINAN, LLP
rushwood, Esq., Id. No.310592
ttorney for Plaintiff