HomeMy WebLinkAbout13-5367 Supreme Court of Pennsylvania
Cous, .l'a m
Comon Pleas
0 CoVe Sheet For Pautlranvtart' USE 01111
Comberland,! �,/ CouutJ7 Docket No:
1
The information collected on this form is used solely for court administration purposes. This form does not
Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin
E Lead Plaintiff Name: Lead Defendant's Name:
C JPMORGAN CHASE BANK, NA MARY JO FABIANKOVITZ
T
I Dollar Amount Requested within arbitration limits
p Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits
Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO
A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C.
❑ Check here if you are a Self-Represented Pro Se Litigant
Nature of the Case Place an "X" to. the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Zoning Board
❑ Product Liability (does not include ❑ Statutory Appeal: Other
E mass tort) ❑Employment dispute:
❑ Slander/Libel Defamation Discrimination
❑ Other ❑Employment Dispute: Other
T ❑ Other:
0 MASS TORT ❑ Other
❑ Asbestos
1 ❑ Tobacco
❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory
❑ Toxic Waste
B ❑Other ❑Eminent Domain/Condemnation Arbitration
❑ Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑ Mandamus
® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order
• Dental ❑ Partition ❑ Quo Warranto
• Legal ❑ Quiet title ❑ Replevin
❑ Medical
❑ Other Professional: ❑ Other ❑ Other
Pa.R.C.P. 205.5 Updated 1/1/2011
KML LAW GROUP, P.C.
SUrrE 5000 - BNY MELLON INDEPENDENCE CENTER FILED-OFFICE
701 MARKET STREET OF THE C R O T H O N O T{ R Y
PHILADELPHIA, PA 19106
(866) 413 -2311 2013 SEP ! i IM", 11. G 7
wWW.KMLLAWGROUP.COM
JPMORGAN CHASE BANK, NA C Ll 11 B E R L " C 0. E_1 t4 7 THE COURT OF COMMON PLEAS
C/O 3415 Vision Drive PENNSYL NIA
Columbus, OH 43219 OF Cumberland COUNTY
Plaintiff
vs. CIVIL ACTION - LAW
MARY JO FABIANKOVITZ
Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE
50 South Enola Drive
Enola, PA 17025
No.
THE UNITED STATES OF AMERICA
Harrisburg Federal Building & Courthouse
228 walnut street, suite 220 ;I'VIL, ACTION: MORJGAGF
Harrisburg, PA 17108
Defendant(s)
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
AVISO
Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243 -9400.
2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website http:// www. phfa. orz /consumers/homeowners /real.a x
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http: / /www_philadelphiafed.org /foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email
at homeretention(a�kmllaw r�oup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 1243261
Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is JPMORGAN CHASE BANK, NA, C/O 3415 Vision Drive, Columbus, OH 43219.
2. The name(s) and property address(es) of the Defendant(s) is /are MARY JO FABIANKOVITZ, 50 South
Enola Drive, Enola, PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged
premises hereinafter described.
3. Defendant, THE UNITED STATES OF AMERICA, is named a Defendant pursuant to 28 U.S.C.
Section 2410, and Plaintiff requests that a judicial sale be held of the Property.
4. On March 01, 2007 mortgagor(s) made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING
SOLELY AS NOMINEE FOR FREMONT INVESTMENT & LOAN, which mortgage is recorded in
the Office of the Recorder of Deeds of Cumberland County on March 13, 2007 as Book 1984 page
4759. The mortgage has been assigned to: JPMORGAN CHASE BANK, NA by assignment of
Mortgage recorded on July 03, 2013 as Instrument #201322118. Plaintiff is the real party in interest
pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of
public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings
if those documents are matters of public record.
5. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ( "Property ").
6. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for April 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
7. The following amounts are due to Plaintiff on the Mortgage as of August 13, 2013:
PrincipalBalance ...................................... ............................... .....................$73,316.70
Variable Interest from 03/01/2013 through 07/31/2013 ......... ......................$3,357.30
AccruedLate Charges ................................. ............................... ........................$707.71
EscrowAdvance ........................................ ............................... ......................$1,275.15
Appraisals................................................... ............................... ........................$202.62
PropertyInspections ..................................... ............................... .........................$28.00
SuspenseBalance .............................................................. ............................... ($243.19)
Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00
$80,294.29
8. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. Plaintiff reserves the right to request
additional attorney's fees if the complexity of the action results in fees in excess of the amount
demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not
limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other
costs of the action in accordance with the mortgage documents and applicable law.
9. Plaintiff is not seeking a judgment of personal liability (or an " persona m " judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
10. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B ". The Defendants have not had the required face -to -face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
11. THE UNITED STATES OF AMERICA, the above named Defendant, has a lien filed of record, set forth
in Exhibit `D' which is attached and made part of this Complaint..
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $80,294.29,
together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited
to attorney's fees and costs, and for the foreclosure and sale of the mortgage property.
B 2d l I
Y•
KML LAW G P, P.C.
Michael c eever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
Pennsylvania Verification
SHANTERIA D. DAVIS , hereby states that he /she is Vice President of
JPMorp_an 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.
SHANTERIA D. DAVIS
Vice President
Date: I - �A' t3
JPMorRan Chase Bank, N.A
Borrower: VA- 1`) D' 5
Property Address: S =
County: C
Last Four of Loan Number: \—1
EythibitA
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ALL THAT CERTAIN lot of ground situate in East Pennsboro Township, Cumberland
County, Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the east side of a public road, formerly the Brick Church
Road, now known as the Enola Drive, at the southwest corner of lot now or formerly of
George D. Wallace; thence eastwardly and through the center of a partition wall between
house on lot hereby conveyed and house on lot adjoining on the north, and beyond a
distance of 125 feet to a point; thence southwardly a distance of 25 feet to a stake; thence
westwardly a distance of 125 feet to a stake, the eastern side of said Enola Drive; thence
northwardly along the eastern line of said Enola Drive a distance of 25 feet to a point, the
Place of BEGINNING.
i
HAVING thereon erected a two story brick and frame dwelling known as No. 50 South
Enola Drive, Enola, Pennsylvania.
UNDER AND SUBJECT to restrictions, conditions and easements of prior record
pertaining to said premises.
BEING THE SAME premises which Amy L. Durham, an adult individual, by her deed
dated the V day of March, 2007 and to be recorded simultaneously herewith, granted and j
conveyed unto Mary Jo Fabiankovitz, a single person, MORTGAGOR herein.
E
*Exhibit has been redacted to remove all personally identifiable information or non-public information
Chase (FL5 -7734) CHASE
P.O. Box 44090 UP
Jacksonville, FL 32231 -4090
May 31, 2013
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
I�IIIIII„ „ III�IIIIIII�I�IIIIII�II
00037343 HDLO ZB 15113 -BW860
MARY J FABIANKOVITZ
50S ENOLA DR
ENOLA, PA 17025
Act 91 Notice
Account: � 785 (the "Loan ")
Property Address: 50S ENOLA DR
ENOLA, PA 17025 (the "Property")
Dear MARY J FABIANKOVITZ:
On the following page, you will find a notice regarding your home as required by Pennsylvania law.
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official Notice that the mortgage on your home is in default, and the lender
intends to foreclose Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
( HEMAP) may be able to help to save your home. This Notice explains how the
program works To see if HEMAP can help, you must MEET WITH A CONSUMER
CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE
DATE OF THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions, you
may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons
with impaired hearing can call 717- 780 - 1869.1
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA
TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR
EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): MARY J FABIANKOVITZ
PROPERTY ADDRESS: 50S ENOLA DR
ENOLA, PA 17025
LOAN ACCOUNT NUMBER: _1785
ORIGINAL LENDER: FREMONT INVESTMENT & LOAN
CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing).
During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ",
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting. The names addresses and telephone numbers of designated consumer
credit counseling agencies for the county in which the property is located are set forth at the end of this Notice
It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default). You
have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the
lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within
thirty (30) days of your face -to -face meeting with the counseling agency.
YOU SHO ULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YO U HA VE A
MEETING WITH CO UNSELING A GENC Y WITHIN THIRTY -THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN
THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROMSTARTINGA FORECLOSURE ACTIONAGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE. "
YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have riled bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to
date).
NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at:
50S ENOLA DR, ENOLA, PA 17025 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
04/01/2013 $923.65
05/01/2013 $923.65
Other charges:
Late Charges: $621.33
Insufficient Funds (NSF) Fees: $0.00
Other Fees: $0.00
Advances: $230.62
Amount Held in Suspense: $243.19
TOTAL AMOUNT PAST DUE: $2,456.06
HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$2,456.06, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check, certified
check or money order made payable and sent to
Overnight/Regular Mail: Chase
Mail Code: OH4 -7133
3415 Vision Drive
Columbus, OH 43219 -6009
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made
within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose
upon your mortgaged property
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have
to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's
fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you
cure the default within the THIRTY (30) -DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default
within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure
the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying
the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs
connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in
writing by the lender, and by performing any other requirements under the mortgage Curing your default in
the manner set forth in this Notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months
from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: Chase
Address: Mail Code: 0114 -7384
3415 Vision Drive
Columbus, 01143219
Telephone Number: 800 - 848 -9380
Fax Number: 614 -500 -4605
Contact Person: Bruno Mejia
E -mail Address: state.programs.intake @jpmchase.com
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale,
a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges,
and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage
are satisfied.
YOU MAY ALSO HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
Advantage Credit Counseling Service /CCCS of 888 -511 -2227 2000 Linglestown Road Harrisburg 17102
Western PA
Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104
Region
Housing Alliance of York/Y Housing Resources 717 - 855 -2752 290 West Market Street York 17401
Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268
Pennsylvania Interfaith Community Programs, 717 - 3341518 40 E. High Street Gettysburg 17325
Inc.
PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110
800 -342 -2397
Rev. 10/12
FM646
We are attempting to collect a debt, and any information obtained will be used for that purpose.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the
attorney's name, address, and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy
under Title 11 of the United States Code, this notice is for compliance and/or informational purposes
only and does not constitute an attempt to collect a debt or to impose personal liability for such
obligation. However, a secured party retains rights under its security instrument, including the right to
foreclose its lien.
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service, you may be eligible for benefits and protections
under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or
eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military
benefits and protections also may be available if you are the dependent of an eligible Servicemember.
Eligible service may include:
Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or
Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or
Active service as a commissioned officer of the Public Health Service, or
Service with the forces of a nation with which the United States is allied in a war or Military action,
or
Service with the National Guard of a state militia under a state call of duty, or
Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause.
For more information, please call Chase Military Services at 877 -469 -0110.
AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS
As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability
Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts
to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in
advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling
888 - 995 -HOPE; 888 - 995 -4673. We offer loan modification assistance free of charge (i.e., no modification fee
required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the
fewer options you may have.
BW860
E ibit
*Exhibit has been redacted to remove all personally identifiable information or non-public information
inst. # 201322118 - Page 1 of 3
CERTIFIED PROPERTY IDENTIFICATION NUNIDERS
09 -15- 1291 -065 - EAST PENNSBORO
} CCGIS REGISTRY 07/03/2013 BY TB
r � ,
Prepared By / Return To:
E.Lance]NTC, 2100 Alt, 19 North,
Palm Harbor, FL 34683
(800)346 - 9152
Loan #: 785
I
i
Tax Code/PIN/UPI #: 09151291065 j
1111111 VIII 11111 IN 111111111111111111111111111111111101
ASSIGNMENT OF MORTGAGE
Contact JPMORGAN CHASE BANK, N.A. for this instrument 780 Kansas Lane, Suite A, Monroe, LA
71203, telephone # (866) 756 -8747, which is responsible for receiving payments.
FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the
undersiggned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
FREMONT INVESTMENT &LOAN ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PO
BOX 2026, FLINT, MI, 48501, (ASSIGNOR), (HERS Address: 1901 E Voorhees Street, Suite C, Danville,
EL 61834) by these presents does convey, grant, assign, transfer and set over the described Mortgagge therein
together with all interest secured thereby, all liens, and any rights due or to become due thereon to 3PMORGAN
CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 Kansas Lane, MC 8000,
MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE).
Said Mortgage is dated 03/012007, in the amount of $75,750,00, made by MARY JO FABIANKOVITZ to
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR FREMONT
INVESTMENT & LOAN, recorded on 03113/2007, in the Office of the Recorder of Deeds of CUMBERLAND
County, Pennsylvania, in Book 1984, Page 4759, and/or Document # n/a..
Property is com onI known as: 50 S ENOLA DR TWP. OF EAST PENNSBORO, ENOLA, PA 17025.
Dated on 3/ 1 2013 (MM/DDIMY)
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR FREMONT
INVESTMENT & LOAN, ITS SUCCESSORS AND ASSIGNS
By:
ASST. SECRETARY
PAGE 1
JPCAS 20715173 — WAMU CJ5156761 N1 MIN 100194430013572527 MERS PHONE 1- 888 - 679 -6377
72713062412 [C] FRMPAI
11111 loll 11111111 illllll {IIII[Illl{IlIIIIE{ 111111 {fllll {Illllllllllflllllll�llll
•D0002058757
is
Inst. # 201322118 - Page 2 of 3 '
I
I
t
i
Loan #: 785
111111111111 IIIII IIIII ill!) 11111111i1 1111111111 IIIII IIII IIII
120 3 (MM/D
STATE 9F LO ISIANA PARISH OF OUACHITA
On
��} Q
CO t D/YYYY), before me appeared .,� L �/�/ / �—s�lT
/
to me personally known, who did say that helshelthey islare the ASST. SECRETARY of MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMWEE FOR FREMONT INVESTMENT & LOAN-
ITS SUCCESSORS AND ASSIGNS and that the instrument was signed on behalf of the corporation (or
association), by authority from its board of directors, and that he/she/they acknowledged the instrument to be the
free act and deed of the corporation (or association).
HELEN P. TUBBS
OU LIFETIME PARISH. CAMNUSSSION A
NOTARY 134 40392
Notary Public - State of LOUISIANA j
Commission expires: Upon My Death
Assignment of Mortgage from:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR FREMONT
INVESTMENT & LOAN ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PO BOX 2026,
FLINT, MI, 48501, (ASSIGNOR), (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834)
to: _
8 00, MONRO , LE A 7$203 (866)756-8747, TS SUCCESSORS OR ASSIGNS, (ASSIGNEE)
Lane, MC
I
Mortgagor. MARY JO FABIANKOV[TZ
When Recorded Return To:
7PMorgan Chase Bank, NA
C/O NTC 2100 Alt. 19 North
Palm Harbor, FL 34683
All that certain lot or piece of ground situated in
Mortgage Premise: 50 S ENO.A DR TWP. OF EAST PENNSBORO
ENOLA, PA 17025
CUMBERLAND
(Borough or Townshi if stated), Commonwealth of Pennsylvania.
Being more articularly described in said Mort age.
1 , hereby certify that the below information and address for the
assignee are correct:
JPMORGAN CHASE 000, MONROE, LA 7103 866)756 8747 ITS SUCCESSORS WHOSE OR ASSIGNS, (ASSIGNEE) nsas Lane, MC
By: -
'r ASST. SECRETARY
PAGE 2
*20715173* JPCAS 20715173 — WAMU CJ5156761 NI MIN 100194430013572527 MERS PHONE
1- 888 - 679 -6377 12713062412 [C] FRMPA 1
IN IN 111111111111011111111 IIIIIIIII11111aIII111111111111N111111IIIIllllllillllllllllllll
D0002058757*
Inst_ # 201322118 - Page 3 of 3
I
ROBERT P. Z1IEGLER AM
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717 -240- 6370�t = ' j
I
Instrument Number - 201322118
Recorded On 7/3/2013 At 10:39:32 AM * Total Pages - 3
• Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 141133 User ID - MBL
• Mortgagor - FABIANKOVITZ, MARY JO
* Mortgagee - JPMORGAN CHASE BANK N A 1
• Customer - SIMPLIFILE LC &RECORDING I
• FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $11.50
RECORDER OF DEEDS This a e is now art
PARCEL CERTIFICATION $15.00 P g P
FEES of this legal document.
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $55.50 i
I Certify this to be recorded
in Cumberland County PA
i c cur .
RECORDER OF DEEDS
nso
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
E (D
*Exhibit has been redacted to remove all personally identifiable information or non-public information
07445008152013 Cumberland County Prothonotary's Office Page 1
Civil Case Inquiry
2012-02362 U S TREASURY DEPARTMENT (vs) FABIANKOVITZ MARY JO
I
Reference No... Filed......... 4/16/2012
Case Type.....: FEDERAL TAX LIEN Time.........: 11:00
Judgment...... 142823.18 Execution Date 0 /00 /0000 j
Judge Assigned: Jury Trial....
Disposed Desc.• Disposed Date. 0 /00 /0000
------ - - - - -- Case Comments --- -- -- ------ Higher Crt 1.:
Higher Crt 2.. I
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
I
General Index Attorney Info
U S TREASURY DEPARTMENT PLAINTIFF
PITTSBURGH OFFICE ROOM 808
1000 LIBERTY AVE f
PITTSBURGH, PA 15222 -9974
I
FABIANKOVITZ MARY JO DEFENDANT
50 S ENOLA DR
ENOLA, PA 17025 - 2704
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
Judgment Index Amount Date Desc
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
FABIANKOVITZ MARY JO 142,823.18 4/16/2012 TAX LIEN
* *
Date Entries
- - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - -
4/16/2012 FEDERAL TAX.LIEN IN THE AMOUNT OF $ 142823.18
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - -
* Escrow Information * �.
* Fees & Debits Beg Bal Pymts /Adj End Bal
FED TAX LIENN 16.50 16.50 .00
AUTOMATION FEE 5.00 5.00 .00
21.50 21.50 .00
i
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
I
End of Case Information
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
i
07451408152013 Cumberland County Prothonotary's Office Page 1
Civil Case Inquiry
2012 -03096 U S TREASURY DEPARTMENT (vs) FABIANKOVITZ MARY JO
Reference No... Filed......... 5/17/2012
Case Type.....: FEDERAL TAX LIEN Time.........: 11:31
Judgment...... 19523.34 Execution Date 0 /00 /0000
Judge Assigned: Jury Trial....
Disposed Deed Disposed Date. 0 /00 /0000
------ - - - - -- Case Comments ---- -- Higher Crt 1.:
Higher Crt 2..
General Index Attorney Info
U S TREASURY DEPARTMENT PLAINTIFF
PITTSBURGH OFFICE ROOM 808
1000 LIBERTY AVE
PITTSBURGH, PA 15222 -9974
FABIANKOVITZ MARY JO DEFENDANT
50 S ENOLA DR
ENOLA, PA 17025-2704 f
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
Judgment Index Amount Date Desc
FABIANKOVITZ MARY. JO 19,523.34 5/17/2012 TAX LIEN
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
*
* Date Entries
_ _ - - - - - FIRST ENTRY - - - - - - - - - - - - - -
5/17/2012 FEDERAL TAX LIEN IN THE AMOUNT OF $ 19523.34
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - -
* Escrow Information
* Fees & Debits Beg Bal Pymts /Adj End Bat
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
i
FED TAX LIEN
16.50 16.50 .00
AUTOMATION FEE 5.00 5.00 .00
- - - - -- - --
21.50 21.50 .00
i
*
* End of Case Information
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
I
I
I
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAIPA
JPMORGAN CHASE BANK, NA -0
Plaintiff'
VS. Case No.
0 ' =2' ��
MARY JO FABIANKOVITZ � _
Defendant(s) __4 -"
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able
to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services
at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal
representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet
with that legal representative within twenty (20) days of the appointment date. During that meeting, you must
provide the legal representative with all requested financial information so that a loan resolution proposal can be
prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached
hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which
must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so
and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender
in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for
a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a
legal representative. However, you must provide your lawyer with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the
format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court,
which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectful
ly subm'tted:
(Signature of Counse Plaintiff)
Dat
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:
VMjL4jy#jj3l MIJIMM H ILKV
Borrower name(s):
Property Address:
City. State:_ Zip:
Is the property for salt? Yes El No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes 11 No
Mailing Address (if different),
City: State: Zip:
Phone Numbers: Office:
Cell: Other:
of people in household How long?
Mailing Address;
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email;
# of people in household: How long?
FINANCIAL lNrolZrV1A'ri0N
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 [] NoED
If yes, provide nannies, location of court, case number & attorney:
Assets Amount Owed Value;
Home: S $
Other heal Estate: $_
Retirement Funds: $ , $ _-
Investments: $
Checking: $
Savings: $ $
Other: $ S
Automobile ril: Model: Year:
Amount owed: Value-
Automobile #2 : Model: 'dear:
Amount owed: Value:
Other traits ortation automobiles boats m torc IlesModel:
year: Amount owed: Value
Monthly Income
Name of .Employers:
l .
2.
3.
Additional Income Description (not. wages):
1. - monthly amount:
2. monthly amount:
Borrower Pay Days: _ ___--- - - - -_. _... _ Co- borrower Pay nays:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
1Mo a e Food
2 Mortgage Utilities
Car Pa ent s Condo/N66. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. loan Payment Cable, TV
Child Su rt/Alirn. Spending Mone
Da /Child Cam/T'uit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes [] No Ej
If yes, please provide the following information;
Counseling Agency:
Couriselor:
Phone, (Office) Fax:
1✓n�eil;
Have you made application for Homeowners Emergency Mortgage Assistance program
(HEMAP) assistance?
yes n No
eyes, 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 M No D
If yes, please indicate the status of these negotiations:
Please provide the folloAbg information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone;
Servicing Company (Name):
Contact: Phone.
TIWe, , authorize the above
named to use /refer this information to my londerlservicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that Itwe am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Bate
Please forward this document along with the following information to leader and
leader's counsel:
�f Proof of income
Past 2 bank statements
Y Proof of any expected income for the last 45 days
Cope of a current utility bill
Letter explaining reason for delinquency and any supporting documentation .
r (bardship letter)
V Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson to`Sheriff
Jody S SmithQti�x �yF�
Chief Deputy sy 13
Richard W Stewart
Solicitor OFFCEOFTK ERI€=
JPMorgan Chase Bank, N.A.
vs. Case Number
Mary Jo Fabiankovitz 2013-5367
SHERIFF'S RETURN OF SERVICE
09/14/2013 11:31 AM- Deputy Shawn Harrison, being duly sworn according to law, serve 9hrequested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint i oreclosure by handing
a true copy to a person representing themselves to be Sandra Smith, h a as"Adult Person in
Charge"for Mary Jo Fabiankovitz at 50 S. Enola Drive, East Pennsbo la17025.
SH WN HAREISEK, DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
September 24, 2013 RbNW R ANDERSON, SHERIFF
fcj Countyguite Sheriff,Teleosot,Inc.
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
JPMORGAN CHASE BANK, NA
C/O 3415 Vision Drive
Columbus, OH 43219
VS.
iE I? 0 THONO TA
2014HAR 7 111111:32
si
OUN y
,N1A
IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
MARY JO FABIANKOVITZ
(Mortgagor(s) and Record owner(s))
50 South Eno la Drive
Eno la, PA 17025
Defendant(s)
THE UNITED STATES OF AMERICA
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
No. 13-5367
KML LAW GROUP, P.C.
F/K/ GOLDBECK McCAFFERTY & McKEEVER
By:
chael McKeever Pa, ID 56129
ay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Thomas Puleo Pa. ID 27615
David Fein Pa, ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello, Attorney ID 313897
Attorneys for Plaintiff
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK, NA
Plaintiff
VS.
MARY JO FABIANKOVITZ
(Mortgagor(s) and Record Owner(s))
Defendant(s)
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE.
No. 13-5367
THE UNITED STATES OF AMERICA
CERTIFICATE OF SERVICE
Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe
to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class
mail, postage pre-paid, on & /
MARY JO FABIANKOVITZ
50 South Enola Drive
Enola, PA 17025
THE UNITED STATES OF AMERICA
Harrisburg Federal Building & Courthouse
228 Walnut Street, Suite 220
Harrisburg,
KML LAW GROUP, P.C.
F/K/A GOLDBECK McCAFFERTY
By:
Angela M. Smith , Legal Assistant
asmith@kmllawgroup.com
215-825-6325 (Direct Phone)
VER