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Home My WebLink About13-5001 For Prothonotary Use Only: S wprem eCourat. -o Pe nnsyIvani�a. .r r Co u 01, P lei s Cb and Docket No. Co u� ty The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E. ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: JPMorgan Chase Bank, N.A. Lead. Defendant's Name: Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C. I ❑ Check here if you have no attorney (a Self - Represented I Pro Sel Litigant) L— - 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 1 ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other i I O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant B REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: gm ❑Eminent Domain /Condemnation ❑ Declaratory Judgm ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order ❑ uo Warranto PROFESSIONAL LIABILITY 11 Mortgage Foreclosure: Commercial Q ❑ Dental 11 Partition 11 Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: i Updated 1/1/2011 p HONO COUNT 3 L 'COUNTY PENNSYLVANI -A McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE -1D # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790 -1010. JPMorgan Chase Bank, N.A. Cumberland County 10790 Rancho Bernardo Road Court of Common Pleas San Diego, CA 92127 - Number V. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. 24 Larch Drive Shippensburg, PA 17257 COMPLAINT IN MORTGAGE FORECLOSURE atn File X174201 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandano a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea . the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisions de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD 'TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 File 4 74201 Page 2 ' COMPLAINT IN MORTGAGE FORECLOSURE R 1. Plaintiff is JPMorgan Chase Bank, N.A. , duly organized and doing business at the above - captioned address. 2. The Defendant is Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr., who is the mortgagor and owner of the mortgaged property hereinafter described, whose last -known address is 24 Larch Drive, Shippensburg, PA 17257. 3. On March 6, 2009, Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr., mortgagor, made, executed and delivered a mortgage upon the premises hereinafter described to JPMorgan Chase Bank, N.A., which mortgage is recorded in the Office ofthe Recorder of Cumberland County as Instrument Number 200907086 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 10 1 9(g) Pa. R. C. P. 4. On March 6, 2009, borrower also executed a promissory note secured by the aforementioned mortgage. Plaintiff, directly or through an agent, is in possession of the note and is the holder of the note with the right to enforce it; the note is either made payable to plaintiff or has been duly endorsed. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 24 Larch Drive, Shippensburg, Pennsylvania 17257. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. file # 74201 Page 3 • 7. The following amounts are due on the mortgage as of 06/17/13: Principal Balance $ 103,184.65 Interest from January 1, 2013 through May 31, 2013 $ 2,364.65 (Plus $15.55 per diem thereafter) Attorney's Fee $ 1,650.00 Escrow Balance $ - 355.39 Property Preservation $ 9.30 Property Inspections $ 280.00 Suspense Balance $ -36.02 GRAND TOTAL $ 107,097.19 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 purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $107,097.19, together with interest at the rate of $15.55 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBER CON AY, P.C. BY: Of [ ] Terrence J. McCabe, squire [ ] Marc S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ C, fieidi'R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph 1. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff File # 74201 Page 4 VERIFICATION hereby states that h sh is Vice President of JPMorgan Chase B nk, N.A. , 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. 1 understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsifications to authorities. Vice President Date: JPMorgan Chase Bank, N.A. , Plaintiff Borrower: Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. Property Address: 24 Larch Drive, Shippensburg, Pennsylvania 17257 County: Cumberland Last Four Digits of Loan Number: 4526 File # 74201 Page 5 EXHIBIT A CTA1049 Exhibit A ALL that certain lot of land situate in Southampton Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described c accordance Deeds with of the Cumberl a d County, Development Plan recorded in the Office of the Recorder o Pennsylvania in Plan Book 68, Page 115, described as follows: BEGINNING at a pin at the common corner of Lots 8�e and heastern edge of Lot $, North 49 degrees the aforementioned Subdivision Plan; thence along 04 minutes 00 seconds West, 130.30 feet to a pin at land now or formerly of Mrs. H.R. Martin, thence 25.87 feet along the southeastern edge of said land, North er140t the along the southe to a pin set at the comer of land now or Y of Sherman Long edge of said land, North 53 degrees 52 minutes n dge a of said Lot 10, South 49 04 of Lot 10 of said Plan; thence along the southwestern thence minutes 00 seconds East, 124.77 feet to a pin set S on outh degrees r 56 minutes 00 se onds West, along the northwestern edge of said Larch Drive, 50.00 feet to a pin set at the corner of Lot 8, the point and place of beginning. CONTAINING 6,449 square feet and BEING all of Lot No. 9 thereon. Y FORM 1 JPMorgan Chase Bank, N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYL V,A&1,X -I CO ; vs. Lloyd W. Welsh., Jr. a /k /a Lloyd Welsh, Jr. Civil Defendant NOTICE OF RESIDENTIAL MORTGAGE FORECLOSVE RE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you, and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectful s miffed: � Date [Signature.of ounsel for Plaintiff] 74201 Page 1 FORM 2 ' Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/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: # of people on household: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? 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 Payment 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. 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 2 " Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuft. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑No❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: 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 obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 EO-OFHC- 0 T F TIIE PROTHONO'Wt: 2013 SEP 13 AM 10* 36 CUMBERLAND COUNTY PENNSYLVANIA McCABE,WEISBERG & CONWAY,P.C. Attorneys for Plaintiff BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ED#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L. MARKOWITZ,ESQUIRE-ID#28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ED#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ED#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ED#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. Number 13-5001 Civil Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh,Jr. Defendant PRAECIPE TO REINSTATE COMPLAINT------\ TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortga orecl ure i ab e-caption d matter. MICA WEISBERG D AY,P. BY: Terrence J.Mc e, q. Marc S eisberg,Esq. Edward D. nw ,Esq. Mar ret Gairo,Esq. Andrew L.Mar owitz,Esq. Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. Christine L. Graham,Esq. Sol, ]fBrian T.LaManna,Esq. Ann E. Swartz,Esq. Lx1joseph F. Riga,Esq. Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff ? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ,�. i) I-IC+ Sheriff � � �� rr4v aS C ir�lr#��, `= i lid PRO�i'#if ti 0 TA t Jody S Smith # Chief Deputy 2613 SEP 255 P11: 42 Richard W Stewart CUMBERLAND � ,,M,., E,QU I Solicitor OF,'K OF TMrs S4ERIF- P E NNS YLVA Pd I A JP Morgan Chase Bank National Association vs. Case Number Lloyd Willard Welsh, JR 2013-5001 SHERIFF'S RETURN OF SERVICE 09/14/2013 06:24 PM- Deputy Shawn Harrison, being duly sworn according to law, served th equested Complaint in Mortgage Foreclosure by"personally" handing a true copy to a perso epre nti g themselves to be the Defendant, to wit: Lloyd Willard Welsh, JR at 24 Larch Drive, Sout H n T nship, Shippensburg, PA 17257. S AWN HA ON, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, September 20, 2013 RbNW R ANDERSON, SHERIFF tc)Co"rtySuito Sheriff,Toleosoft,Inc. McCABE,WEISBERG& CONWAY,P.C. BY: HEIDI R. SPIVAK,ESQUIRE-ID#74770 z44,3 i NOV 14 123 South Broad Street,Suite 1400 "'IrDW n Philadelphia,Pennsylvania 19109 PNNS' LD NO U !<( (215) 790-1010 JPMorgan Chase Bank,N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-5001 Civil Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh,Jr. Defendant MOTION TO LIFT STAY OF PROCEEDINGS Plaintiff, JPMorgan Chase Bank,National Association , hereby motions this Court to remove the captioned mortgage foreclosure action from the Cumberland County Residential Mortgage Foreclosure Program("the Program"),and in support thereof avers as follows: 1. This is an action in mortgage foreclosure brought by JPMorgan Chase Bank, National Association against Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh,Jr.. 2. This case is currently under a stay pursuant to paragraph (b) of the Cumberland County Administrative Order dated February 28, 2012, which establishes the Mortgage Foreclosure Diversion Program. 3. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. was served a true and correct copy of the original complaint in mortgage foreclosure,filed on August 22,2013 to his last known address of 24 Larch Drive, Shippensburg, Pennsylvania 17257. A true and correct copy of the Sheriff's return of service is attached hereto as Exhibit"A". 4. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet on September 14,2013 to his last known address of 24 Larch Drive, Shippensburg, Pennsylvania 17257. A true and correct copy of the Notice of Residential Mortgage Foreclosure Diversion Program is attached hereto as Exhibit"B". 5. It has been more than sixty days since Defendant(s) was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet and Defendant(s)has not elected to participate in the Program by taking the affirmative steps identified in the Notice of Residential Mortgage Foreclosure Diversion Program,and has not filed a Request for Conciliation Conference. 6. For the reasons set forth herein,the aforementioned stay of proceedings should be lifted to allow Plaintiff to proceed with the instant mortgage foreclosure action. WHEREFORE, it is respectfully requested that the Court enter an Order lifting the stay of proceedings, and for such further relief as the Court deems appropriate. MCCABE, WEISBERG&CONWAY,P.C. By: M 44' , Esquire (V1APC. 1/j32-1 • McCABE,WEISBERG AND CONWAY,P.C. BY: Heidi R. Spivak,Esquire,Atty I.D.#74770 Attorneys for Plaintiff 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-5001 Civil Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh, Jr. Defendant CERTIFICATE OF SERVICE I, Heidi R. Spivak, Esquire, hereby certify that a true and correct copy of Plaintiff's Motion to Lift the Stay of Proceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012, was served on the below named person(s)by regular first class mail, postage prepaid, on November 13, 2013. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. 24 Larch Drive Shippensburg, Pennsylvania 17257 D t d 11 13 a 4 3 / c tt-1- ae . ,Esquire ARC' g ►g 6e_ 6-- • EXHIBIT A SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1),, L Ronny R Anderson LA, •0 Sheriff Ot ell/I/41 449‘) Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICEaFTHIi EMERIF F JP Morgan Chase Bank National Association vs. Case Number Lloyd Willard Welsh, JR 2013-5001 SHERIFF'S RETURN OF SERVICE 09/14/2013 06:24 PM-Deputy Shawn Harrison, being duly sworn according to law, served th- equested Complaint in Mortgage Foreclosure by"personally"handing a true copy to a perso epre nti g themselves to be the Defendant,to wit: Lloyd Willard Welsh, JR at 24 Larch Drive, Sout •-n T• nship, Shippensburg, PA 17257. S AWN HA"."" ON, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, September 20, 2013 RON R ANDERSON, SHERIFF • (c)CounlySuilo Sherifl,'feleocoff,Inc. EXHIBIT B • FORM I JPMorgan Chase Bank,N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, P1 NNSV L"VANIA ._ vs. -'17::;�,:'i '•in Lloyd W. Welsh,Jr.a/IJa Lloyd Welsh, Jr. Civil _<? r`' t Defendant ,-i:} `r - C—, _.". �c NOTICE OF RESIDENTIAL MORTGAGE FORECLURE L DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference.First, within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you,and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.THIS PROGRAM IS FREE. Respectful y s ljmitted: 110 Date [Signature of ounsel for Plaintiff] 74x01 Page 1 FORM 2 • Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: 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: #of people on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? 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 Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes❑No❑ If yes,provide names, location of court,case number&attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles,boats,motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 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/Alim. Spending 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 0 No 0 If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes❑No❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes❑No❑ If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: 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 obiligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: f Proof of income Past 2 bank statements 1 Proof of any expected income for the last 45 days 1 Copy of a current utility bill i Letter explaining reason for delinquency and any supporting documentation(hardship letter) Listing agreement(if property is currently on the market) 3 W THE rPROTNCNC AT :' McCABE,WEISBERG& CONWAY,P.C. BY: HEIDI R. SPIVAK,ESQUIRE-ID#74770 2013 NOY 20 A 9: 4 7 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 CUMBERLAND COUNTY (215) 790-1010 PENNSYLVANIA JPMorgan Chase Bank,N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-5001 Civil Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh,Jr. Defendant ORDER AND NOW,this / ' day of AJovi.✓ -.-' 20/3 , upon consideration of Plaintiff's Motion to Lift the Stay of Proceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012, and any opposition thereto, it is hereby ORDERED and DECREED that: The stay of proceedings is hereby lifted, and Plaintiff may proceed with it's action in mortgage foreclosure in accordance with the applicable rules of civil procedure. BY THE COURT: 61-A4 J. Cei•EJS 1.SCL, - 11. i V AL nal(L. tOris /��ac3A3 McCABE,WEISBERG AND CONWAY,P.C. ° BY:• TERRENCE J.McCABE,ESQUIRE-ID# 16496 , Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 ; i _ �. � MARGARET GAIRO,ESQUIRE-ID# 34419 � � � � ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 n MARISA J.COHEN,ESQUIRE-ID#87830 �0 l � a ((; Q CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321U�"[ � �a`1NQ COUNTY ANN E.SWARTZ,ESQUIRE-ID#201926 PENNSYLVANIA JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 201.3-05001. Lloyd W.Welsh,Jr. Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Lloyd W.Welsh,Jr.,in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount due $ 107,097.19 Interest from 06/01/13 to 01/06/14 $ 3,421.00 Total $ 110,518.19 McCABE,WEISBERG VD CONW Y,P.C. BY: rnb(.('./a(J [ ]Terrence J.McCabe,Esq. [•}-1171V6 S.Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire JO Attorneys for Plaintiff JO AND NOW,this day of ,\A ` . ,2014,Judgment is entered in favor of Plaintiff,JPMorgan Chase Bank,N.A. ,and against Defendant,Lloyd W. Welsh,Jr., in rem only and not in personam, and damages are assessed in the amount of$110,518.19,plus interest and costs. BY THE • •OT • TA ,\.At Lpv- °Lk dbtAN) S0�'a 1„ McCABE,WEISBERG AND CONWAY,P.C. BY:' TERRENCE J.McCABE,ESQUIRE-ID# 1 6496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Lloyd W.Welsh,Jr. Defendant Number 2013-05001 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Lloyd W. Welsh, Jr., is 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.App. §501, et seq.;and that the Defendant,Lloyd W.Welsh,Jr., is over eighteen(18)years of age,and resides as follows: Lloyd W.Welsh,Jr. 24 Larch Drive Shippensburg,PA 17257 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED C //4 ! W BY: ////CC// BEFORE ME THIS Pk DAY [ ]Terrence J.McCabe,Esq. [ Marc. .Weisberg,Esq. [ ]Edward D. Conway,Esq. [ ]Margaret Gairo,Esq. OF ,1e-�� ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. v [ ]Marisa J. Cohen,Esq. [ ]Christine L.Graham,Esq. if/4v -Tizobj [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph 1.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL Attorneys for Plaintiff DEAN R.JACOBS,JR.,Notary Public City of Philadelphia,.Phila.County My Comniission..Expiies June 27,2017 , Department of Defense Manpower Data Results as of:Jan-06-2014 08:10:02 Center SCRA 3.0 ` +�' Status Report ';?~ , P ' ursuant to Servicemembers Civil Relief Apt Last Name: WELSH, JR. First Name: LLOYD Middle Name: W. Active Duty Status As Of: Jan-06-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA •6A•' ■ 1 _ ',1t 1 'r'No . NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA Pl NA No • I NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date �� . - L I_r t The Member or HistHer 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- 4' No• 0 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,NOM,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 I■ • • 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: H65EU7C8W0626E0 McCABE,WEISBERG AND CONWAY,P.C. BY:• TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 2013-05001 Lloyd W.Welsh,Jr. Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: • SS. COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last-known mailing address of the Defendant is: Lloyd W. Welsh,Jr. 24 Larch Drive Shippensburg,Pennsylvania 17257 McCABE, ISBERG AN CONWA' ,P.C. SWORN AND SUBSCRIBED �� BEFORE ME THIS 6 DAY [ ]Terrence .McCabe, [ Iarc S(Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF ,,u,. .,/ ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. I / [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. 17,,6b [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P. DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL Attorneys for Plaintiff DEAN R.JACOBS.JR.,Notary Public City of Philadelphia,Phila.County My CommissionErpires June 27,2017 A ' y • McCABE,WEISBERG AND CONWAY,P.C. BY:• TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 2013-05001 Lloyd W. Welsh,Jr. Defendant CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff,being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND ONWAY,P.C. SWORN AND SUBSCRIBED BY: , �4 t BEFORE ME THIS 44%. DAY [ ]Terrenc J.McCabe,Esq. [ ]mac S. eisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF l u 4-\ ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. V [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUB IC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL Attorneys for Plaintiff DEAN R.JACOBS,JR.,Notary Public City of Philadelphia,Phila.County My Commission.Expires June 27,2017 • VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsification to authorities. McCABE,WEISBERG AND�CONW Y,P.C. BY: e [ ]Terrenc J.McCabe,Esq. [.....)-Marc .Weisberg,Esq. [ .]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff JPMorgan Chase Bank,N.A. v.Lloyd W.Welsh,Jr. Cumberland County;Number: 2013-05001 .. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse,Carlisle, Pennsylvania 17013 Curt Long Prothonotary December 3,2013 To: Lloyd W. Welsh, Jr. a/k/a Loyd Welsh,Jr 24 Larch Drive Shippensburg, Pennsylvania 17257 JPMorgan Chase Bank, N.A. Cumberland County vs. Court of Common Pleas Lloyd W. Welsh,.Jr. a/k/a Loyd Welsh,Jr Number 2013-05001 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA PORNO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 FOR ABOGADO Y FOR NO HABER RADICADO FOR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(1 0) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERTY ACC10N DEBiDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE F.STA OR OTHER IMPORTANT RIGHTS. NOTIFIC,AC.ION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO HOT HAVE A LAWYER,GO TO OR TELEPI-IONE THE OFFICE SET FORTH SENTENCIA EN S U CONTRA V USTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER,TIIIS OFFICE MAY BEADLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS ATA REDUCED FEE OR NO FEE. PROPORCIONAR CAN INFORMACION ACERCA DE EMPLIiAR A UN ABOGADO. • Cumberland County Bar Association SI USTED NO PUEDE PROPORCIONAR PARAEMPLEARUNABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DC PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DEI.ASAGRNCIASQUEPUEDENOFRECERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,WEISBERG AND CONWAY,P.C. BY: ■ [ ]Terrence J. McCabe,Esquire arc S. Weisberg,Esquire [ ]Edward D.Conway, Esquire argarct Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ] eidi R.Spivak,Esquire [ ] Marisa J.Cohen,Esquire [4CChristine L. Graham, Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff mjs t_ EXhib;1 t. . . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Lloyd W. Welsh,Jr. 24 Larch Drive Shippensburg,Pennsylvania 17257 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. Number 2013-05001 Lloyd W. Welsh,Jr. Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary ;,.R /' X Judgment by.Default Money Judgment ‘\ibl Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.:2013-05001 Civil Term JPMorgan Chase Bank,N.A. V. AMOUNT DUE: $110,518.19 x" ' Lloyd W.Welsh,Jr.a/k/a Lloyd Welsh,Jr. INTEREST:from 01/07/14 Z-;0 , $2,707.33 at$18.17 —� Y ATTY'S COMM.: Cam" COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 24 Larch Drive Shippensburg,Pennsylvania 17257 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 9 1 la BY: [ ]Terrence J.McCabe,Esq. [ arc S.W sberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. •SO 1 [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. Joseph L Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff u Firm:MCCABE,WEISBERG AND CONWAY • S Address:123 S.Broad Street,Suite 1400 Philadelphia,PA 19109 Attorney for:Plaintiff Telephone: 215 790 1010 Supreme Court ID No. ,. LL- le Ll L Au?(x WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-5001 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,N.A.Plaintiff(s) From LLOYD W.WELSH,JR.A/K/A LLOYD WELSH,JR. (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $110,518.19 L.L.: $.50 Interest FROM 01/07/14-$2,707.33 AT$18.17 Atty's Comm: Due Prothy: $2.25 Atty Paid: $211.10 Other Costs: Plaintiff Paid: Date: 1/27/14 2UZZL David D. Buell,Prothonotary (Sea])' ' Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Southampton Township,Cumberland County,Commonwealth of Pennsylvania,more particularly bounded and described in accordance with the Larch Drive Land Development Plan recorded in the Office of the Recorder of Deeds of Cumberland County,Pennsylvania in Plan Book 68, Page 115,described as follows: BEGINNING at a pin at the common corner of Lots 8,9 and the northwestern edge of Larch Drive on the aforementioned Subdivision Plan;thence along the northeastern edge of Lot 8,North 49 degrees 04 minutes 00 seconds West 130.30 feet to a pin at land now or formerly of Mrs. H. R. Martin;thence along the southeastern edge of said land North 40 degrees 54 minutes 07 seconds East,25.87 feet to a pin set at the corner of land now or formerly of Sherman Long;thence along the southeastern edge of said land,North 53 degrees 52 minutes 07 seconds East 24.75 feet to a pin set at the corner of Lot 10 of said Plan;thence along the southwestern edge of said Lot 10, South 49 degrees 04 minutes 00 second East, 124.77 feet to a pin set on the northwestern edge of Larch Drive;thence along the northwestern edge of Larch Drive, South 40 degrees 56.minutes 00 seconds West, 50.00 feet too a pin set at the corner of Lot 8,the point and place of beginning. CONTAINING 6,449 square feet and BEING all of Lot No. 9 thereon. AND, Shannon J. Horn, spouse of David J. Horn,joins in this deed for the purpose of conveying the premises described herein free and clear of any and all potential future claim, in the event of a divorce or an annulment, that the premises or the proceeds,or any portion of either of them are"marital property"as the term is defined in the Pennsylvania Divorce Code. SUBJECT TO any and all existing rights of way,conditions,easements,restrictions,reservations,rights, agreements,notes and other matter of record to the extent valid and enforceable and still applicable to the above-described premises. 124 Larch Drive, Shippensburg,Pennsylvania 17257. BEING the same premises which DAVID J. HORN,JOINED BY SHANNON J. HORN,HIS WIFE by deed dated March 6, 2609 and recorded March 11,2009 in the Office of the Recorder in and for Cumberland County in Deed Instrument#200907085 granted and conveyed to Lloyd W.Welsh,Jr. a/k/a Lloyd Welsh,Jr., in fee. TAX MAP PARCEL NUMBER: 39-35-2385-074 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 ' r' KEVIN T.McQUAIL,ESQUIRE-ID#307169 jz. CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 r ? CEL'INE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,l Pennsylvania 19109 215 790-1010 JPMorgan Chase Bank,N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 2013-05001 Lloyd W.Welsh,Jr. a/k/a Lloyd Welsh,Jr. Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at:24 Larch Drive,Shippensburg,Pennsylvania 17257,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Lloyd W.Welsh,Jr.,a/k/a Lloyd 24 Larch Drive Welsh,Jr. Shippensburg,Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Lloyd W.Welsh,Jr.a/k/a Lloyd 24 Larch Drive Welsh,Jr. Shippensburg,Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein JPMorgan Chase Bank,National 10790 Rancho Bernardo Road Association San Diego,California 92127 , 4. Name and address of the last recorded holder of every mortgage of record: Name Address JPMorgan Chase Bank,National 10790 Rancho Bernardo Road Association San Diego,California 92127 Members 1st Federal Credit Union P.O.Box 40 Mechanicsburg,Pennsylvania 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None i 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: i Name Address Tenants/Occupants 24 Larch Drive Shippensburg,Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales i United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 i Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 i Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904'relating to unsworn falsification to authorities. / v BY: Terrence J.McCabe,Esq. [ arc S.Weisb rg,Esq. D TE [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph L Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Southampton Township, Cumberland County, Commonwealth of Pennsylvania,more particularly bounded and described in accordance with the Larch Drive Land Development Plan.recorded in�the Office of the Recorder of Deeds of Cumberland County,Pennsylvania in Plan Book 68, Page 115,described as follows: BEGINNING ai a pin at the common corner of Lots 8,9 and the northwestern edge of Larch Drive on the aforementioned .Subdivision Plan;thence along the northeastern edge of Lot 8,North 49 degrees 04 minutes 00 seconds West 130.30 feet to a pin at land now or formerly of Mrs. H.R.Martin;thence along the southeastern edge of said land North 40 degrees 54 minutes 07 seconds East,25.87 feet to a pin set at the corner of land now or formerly of Sherman Long;thence along the southeastern edge of said land,North 53 degrees 52 minutes 07 seconds East 24.75 feet to a pin set at the corner of Lot 10 of said Plan;thence along the southwestern edge of said Lot 10, South 49 degrees 04 minutes 00 second East, 124.77 feet to a pin set on the northwestern edge of Larch Drive;thence along the northwestern edge of Larch Drive, South 40 degrees 56 minutes 00 seconds West, 50.00 feetto a pin set at the corner of Lot 8,the point and place of beginning. CONTAINING 6,449 square feet and BEING all of Lot No. 9 thereon. AND, Shannon J. Horn, spouse of David J.Horn,joins in this deed for the purpose of conveying the premises described hereinlfree and clear of any and all potential future claim, in the event of a divorce or an annulment, that the premises or the proceeds, or any portion of either of them are"marital property"as the term is defined in the Pennsylvania Divorce Code. SUBJECT TO any and all existing rights of way, conditions, easements,restrictions,reservations,rights, agreements,notes and other matter of record to the extent valid and enforceable and still applicable to the above-described;premises. 124 Larch Drivel Shippensburg,Pennsylvania 17257. BEING the same premises which DAVID J.HORN,JOINED BY SHANNON J.HORN,HIS WTFE by deed dated March 6,2009 and recorded March 11, 2009 in the Office of the Recorder in and for Cumberland County in Deed Instrument#200907085 granted and conveyed to Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh,Jr., in fee. TAX MAP PARCEL NUMBER: 39-35-2385-074 I McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 ., HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 "x= , BRIAN T.LaMANNA,ESQUIRE-ID#310321 ,�' f ANN E.SWARTZ,ESQUIRE-ID#201926 <�-• �_ + JOSEPH F.RIGA,ESQUIRE-ID#57716 •C � �c:, JOSEPH I.FOLEY,ESQUIRE-ID#314675 71 CELNE P.DERKRIKORIAN,ESQUIRE-ID#313673E c' > 123 South Broad Street,Suite 1400 " Philadelphia Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW JPMorgan Chase Bank,N.A. COURT OF COMMON PLEAS i V. CUMBERLAND COUNTY Lloyd .Welsh Jr. a/k/a Lloyd Welsh Jr. oyd y , Number 2013-05001 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lloyd W.Welsh,Jr.a/k/a Lloyd Welsh,Jr. 24 Larch Drive Shippensburg,Pennsylvania 17257 Your house(real estate)at 24 Larch Drive,Shippensburg,Pennsylvania 17257 is scheduled to be sold at Sheriffs Sale on June 4,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland Bounty Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$110,518.19 obtained by JPMorgan Chase Bank,N.A. 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 canceled if you pay to JPMorgan Chase Bank,N.A. the back payments,late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 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. i 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 the following notice 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 McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 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 on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C.at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate 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,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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Southampton Township, Cumberland County, Commonwealth of Pennsylvania,more particularly bounded and described in accordance with the Larch Drive Land Development Plan recorded in the Office of the Recorder of Deeds of Cumberland County,Pennsylvania in Plan Book 68, Page 115, described as follows: BEGINNING at a pin at the common corner of Lots 8,9 and the northwestern edge of Larch Drive on the aforementioned Subdivision Plan; thence along the northeastern edge of Lot 8,North 49 degrees 04 minutes 00 seconds West 130.30 feet to a pin at land now or formerly of Mrs.H.R. Martin;thence along the southeastern edge of said land North 40 degrees 54 minutes 07 seconds East,25.87 feet to a pin set at the corner of land now or formerly of Sherman Long;thence along the southeastern edge of said land,North 53 degrees 52 minutes 07 seconds East 24.75 feet to a pin set at the corner of Lot 10 of said Plan;thence along the southwestern edge of said Lot 10, South 49 degrees 04 minutes 00 second East, 124.77 feet to a pin set on the northwestern edge of Larch Drive;thence along the northwestern edge of Larch Drive, South 40 degrees 56 minutes 00 seconds West, 50.00 feet to a pin set at the corner of Lot 8,the point and place of beginning. CONTAINING 6,449 square feet and BEING all of Lot No.9 thereon. AND, Shannon J.Horn,spouse of David J.Horn,joins in this deed for the purpose of conveying the premises described herein free and clear of any and all potential future claim, in the event of a divorce or an annulment, that the premises or the proceeds, or any portion of either of them are"marital property"as the term is defined in the Pennsylvania Divorce Code. SUBJECT TO any and all existing rights of way,conditions, easements,restrictions,reservations,rights, agreements,notes and other matter of record to the extent valid and enforceable and still applicable to the above-described premises. 124 Larch Drive, Shippensburg, Pennsylvania 17257. BEING the same premises which DAVID J.HORN,JOINED BY SHANNON J.HORN,HIS WIFE by deed dated March 6, 2009 and recorded March 11, 2009 in the Office of the Recorder in and for Cumberland County in Deed Instrument#200907085 granted and conveyed to Lloyd W. Welsh,Jr. a/k/a Lloyd Welsh, Jr., in fee. TAX MAP PARCEL NUMBER: 39-35-2385-074 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE -1D # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 JPMorgan Chase Bank, N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 2013 -05001 Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. Defendant AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 7th day of April, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS j I, DAY OF Re y A , 2014 McCABE, ISBERG &iY, P.C. BY:/ pig Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff NOTARY PUB ,coMMQmA [ ] Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi. R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 JPMorgan Chase Bank, N.A. Plaintiff v. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2013 -05001 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 24 Larch Drive, Shippensburg, Pennsylvania 17257, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Lloyd W. Welsh, Jr., a/k/a Lloyd 24 Larch Drive Welsh, Jr. Shippensburg, Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Lloyd W. Welsh, Jr. a/k/a Lloyd 24 Larch Drive Welsh, Jr. Shippensburg, Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File #74201 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein JPMorgan Chase Bank, National Association Address 10790 Rancho Bernardo Road San Diego, California 92127 Members 1st Federal Credit Union P.O. Box 40 Mechanicsburg, Pennsylvania 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Southampton Township 20 Airport Road Shippensburg PA 17257 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: Name Tenants /Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance. Lien Section Address 24 Larch Drive Shippensburg, Pennsylvania 17257 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8' Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 PO BOX 280948 Harrisburg PA 17128 -0948 File #74201 Page 2 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriffs Sales do United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 U.S. Dept. of Justice, Rm 4400 950 Pennsylvania Avenue, NW Washington, DC 20530 U.S. Dept. of Justice, Rm 5111 950 Pennsylvania Avenue, NW Washington, DC 20530 Address File #74201 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE McCABE, WEISBERG & CONWAY, P.C. BY: Terrence J. McCabe, Esquire ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff [ ] Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire Re: JPMorgan Chase Bank, N.A. v. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. et al. Cumberland County; Number: 2013 -05001 File #74201 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 JPMorgan Chase Bank, N.A. Plaintiff v. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 2013 -05001 DATE: April 7, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. PROPERTY: 24 Larch Drive, Shippensburg, Pennsylvania 17257 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $110,518.19 The above - captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on June 4, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 ATTN: S. Wiltbanks 74201 Check type of mail 0 Certified 0 COD 0 Delivery Confirmation 0 Express Mail CI Insured or service: Recorded Delivery (International) Registered 0 Return Receipt for Merchandise 0 Signature Confirmation U.S. POSTAGE> »PITNEY BOWES P 19109 n77 Qn0 Line Article Number Postage '1112.g116211" . 0001377494 APR. 07. 2014 F 1 JPMorgan Chase Bank, N.A. Plaintiff v. Lloyd W. Welsh, Jr. a/k/a Lloyd Welsh, Jr. Defendant Tenants /Occupants 24 Larch Drive Shippensburg, Pennsylvania 17257 2 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 3 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8`h Street Suite #204 Philadelphia, PA 19107 4 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 5 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 • 6 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 7 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128 -0948 8 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg. PA 17128 -1230 ATTN: Sheriffs Sales 9 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 10 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 11 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 12 Commonwealth of PA Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriffs Sales 13 + _ United States of America do United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 14 United States of America c/o United States Attorney for the 2010 -5387 District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 15 United States of America do Attv General of the United States U.S. Dept of Justice. Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 16 United States of America c/o Attv General of the United States U.S. Dent of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 17 Southampton Township 20 Airport Road Shippensburg PA 17257 18 Members 1st Federal Credit Union P.O. Box 40 Mechanicsburg, Pennsylvania 17055 19 JPMorgan Chase Bank, National Association 10790 Rancho Bernardo Road San Diego, California 92127 Total Number of Pieces Listed by Sender 19 Total mks Recei a ost O ,y . . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny 0Anderson - Sheriff � !r / . � Ti��!.'� ..`. Jody SGm�h 4,4 Chief Deputy r ��b /!U | � F�� 7 '.� Richard W Stewart r:1J r ��J �]:�r`' Solicitor 04:f ~ u ^ ' pEN SYU/A N!A JP Morgan Chase Bank National Association vs. Case Number Lloyd Willard Welsh a/k/a Lloyd Welsh, JR 2013-5001 SHERIFF'S RETURN OF SERVICE 03/28/2014 12:40 PM -Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 24 Larch Drive, Southampton -Township, Shippensburg, PA 17257, Cumberland County. 04/03/2014 12:28 PM-Deputy Stephen Bendar, being duly sworn according to law, served the requested Real Estate Writ, Notice and Oeouription, in the above titled aution, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Lloyd Willard Welsh a/k/a Lloyd VVe|oh, JR at 24 Larch Drive, South Hampden Townoh|p, Shippenaburg, PA 17257, Cumberland County. 86/04/2014 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland CCourthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of$1.00 to Attorney Terrance PNoCabe, on behalf of, JPMorgan Chase Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1.306.65 SO ANSWERS, X. June 24, 2014 RONIFR ANDERSON, SHERIFF 'c/�� • �� x�d' `�&�� ~ =�� ==~-p�� ' � Jr_ ^ '� ��, 1 �~ .^� »^�'. ~ �� ^= �� r^**=�'"" 10/1 (y.7;19 On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in `` [Southampton Township, Cumberland County, PA, cr Known and numbered as 24 Larch Drive, C-- N Shippensburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Jet-tkcie i • tc Real Estate Coordinator Alp LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-5001 Civil Term premises described herein free and clear of any and all potential future JP Morgan Chase Bank claim,in the event of a divorce or an National Association annulment,that the premises or the vs. proceeds, or any portion of either of Lloyd Willard Welsh a/k/a them are "marital property" as the Lloyd Welsh,Jr.,JR term is defined in the Pennsylvania Divorce Code. Atty.: Terrence McCabe SUBJECT TO any and all existing ALL THAT CERTAIN lot of land rights of way,conditions,easements, situate in Southampton Township, restrictions, reservations, rights, Cumberland County,Commonwealth agreements,notes and other matter of Pennsylvania, more particularly of record to the extent valid and en- bounded and described in accor- forceable and still applicable to the dance with the Larch Drive Land above-described premises. Development Plan recorded in the 24 Larch Drive, Shippensburg, Office of the Recorder of Deeds of Pennsylvania 17257. Cumberland County, Pennsylvania BEING the same premises which in Plan Book 68,Page 115,described DAVID J.HORN,JOINED BY SHAN- as follows: NON J. HORN, HIS WIFE by deed BEGINNING at a pin at the corn- dated March 6, 2009 and recorded mon corner of Lots 8, 9 and the March 11, 2009 in the Office of northwestern edge of Larch Drive the Recorder in and for Cumber- on the aforementioned Subdivision land County in Deed Instrument Plan; thence along the northeastern #200907085 granted and conveyed edge of Lot 8, North 49 degrees 04 to Lloyd W. Welsh, Jr. a/k/a Lloyd minutes 00 seconds West 130.30 Welsh,Jr.,in fee. feet to a pin at land now or formerly TAX MAP PARCEL NUMBER: 39- of Mrs. H. R. Martin; thence along 35-2385-074. the southeastern edge of said land North 40 degrees 54 minutes 07 seconds East,25.87 feet to a pin set at the corner of land now or formerly of Sherman Long; thence along the southeastern edge of said land,North 53 degrees 52 minutes 07 seconds East 24.75 feet to a pin set at the corner of Lot 10 of said Plan;thence along the southwestern edge of said Lot 10,South 49 degrees 04 minutes 00 second East, 124.77 feet to a pin set on the northwestern edge of Larch Drive;thence along the northwestern edge of Larch Drive,South 40 degrees 56 minutes 00 seconds West, 50.00 feet to a pin set at the corner of Lot 8,the point and place of beginning. CONTAINING 6,449 square feet and BEING all of Lot No. 9 thereon. AND, Shannon J. Horn, spouse of David J. Horn,joins in this deed for the purpose of conveying the 118 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. '_ r i's- Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 2 da of Ma 2014 401 / , / j- Notary COMMONWEALTH OF PENNSYLVANIA LNOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE B0R0.,CUMBERLAND CNTY Mi Commission Expires Apr 28. 2018 -The Patriot-News Co. 2020 Technology Pkwy e p atriotNews tr Suite 300 'Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds ^auphin in Miscellaneous Book"M", Volume 14, Page 317. )fuse esey�ye�ioyr dP l IIMO 1OOS-C10Z 20154001 Civil Term ( This ad ran on the date(s)shown below: JP Morgan Chase Bank • National Association 04/13/14 Vs • 04/20/14 Uoyd Willard Welsh a/k/a / Uoyd Welsh,Jr.,JR 04/27/14 Atiy: Terrance McCabe / ALL THAT CEirrAl f tot of land - situate in Southampton Township, Cumbe -,d County,Commonwealth of Pe. more Particularly Sworn ti and subscribed befog e t ' 02 day of May, 2014 A.D. bound and described in accordance I with a Larch Drive Land I ' ' Devefo•. eat Plan recorded in the • 1.1� '_ - ' _6. Office of the Recorder of Deeds o€ ota PU`blic— Cumberland County,Pdennsylvania in Plan Book 68,Page as follows: BEGINNING at a pin at the . co,, a„,,, common corner of Lots 8,9 and the northwestern ed• ge of Larch Drive on MS'fGi{i tl. ;err - nn .G COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which JPMorgan Chase Bank, NA is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 27th day of January, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 5001, at the suit of JPMorgan Chase Bank, NA against Lloyd W. Welsh Jr. a/k/a Lloyd Welsh Jr. is duly recorded as Instrument Number 201415536. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /71'7 day of A.D. k kfaj 5.0.- Recorder of Deeds • ..r of Deeds,Cumberland County,Carlisle,PA My . mission Expires the First Monday of Jan.2018