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Home My WebLink About13-5368 Supreme Court of Pennsylvania Coui fy:6,if Cotiimon Pleas ' Fc?r P�atlao aoMIT Lisa Or11t�_. Ctii� al:C oceI Sheet 4 . cu,mberlsty `. County �o��t�a: _ _ _ _____ 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 Taking E Lead Plaintiff Name: Lead Defendant's Name: JPMORGAN CHASE BANK, NATIONAL LEON L. GRICKIS JR C ASSOCIATION SBM CHASE HOME FINANCE LLC LISA OTTO T SBM TO CHASE MANHATTAN MORTGAGE CORP. I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO A Name of Plaintiff/appellant's Attorney: 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 � mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: I Q MASS TORT ❑ Other ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS • Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory • Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ 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.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CENTER r 41 - • r �' t j 701 MARKET STREET ''i � a � ��.. �, . r ry- �✓ PHILADELPHIA, PA 19106 (866) 413 -2311 ii; I P A H ! r} ) JPMORGAN CHASE BANK, NATIONAL iJ IN THE COURT OF COMMON PLEAS ASSOCIATION SBM CHASE HOME FINANCE LLC P E A S�yt Cumberland COUNTY SBM TO CHASE MANHATTAN MORTGAGE CORP. OF Cu 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION - LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE LEON L. GRICKIS JR LISA OTTO No. Mortgagor(s) and Record Owner(s) 1043 Northfield Drive CIVIL ACTION: MORTbA. Carlisle, PA 17013 FORg,Ci OSURE 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 han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial 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 DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME s d CI V sssq POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR 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.hudgov 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.org/ consumers /homeowners /real.aspx 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.12hiladelphiafed.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 homeretentiongkmllaw rgroup.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 123961FC. 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, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are LEON L. GRICKIS JR, 1043 Northfield Drive, Carlisle, PA 17013 and LISA OTTO, 1043 Northfield Drive, Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 12, 2003 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to CHASE MANHATTAN MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 13, 2003 as Book 1800 page 2495. 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. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property ") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 01, 2012 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. 6. The following amounts are due to Plaintiff on the Mortgage as of August 1, 2013: Principal Balance ..................................... ............................... ....................$101,751.36 Interest from 03/01/2012 through 07/31/2013 ........................ ......................$2,883.03 AccruedLate Charges ................................. ............................... ........................$156.64 EscrowAdvance ........................................ ............................... ......................$3,022.08 BPO/ Appraisals ................................................................... ............................... $250.00 PropertyInspections .................................... ............................... ........................$158.58 Suspense Balance .............................................................. ............................... ($667.98) ProperyPreservation .................................... ............................... .........................$70.00 Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $109,273.71 7. If the Mortgage is reinstated prior to a Sheriffs 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. 8. Plaintiff is not seeking a judgment of personal liability (or an " personam '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. 9. 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. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $109,273.71, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW GR UP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 drew F. Gornall Pa. ID 92382 A L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Pennsylvania Verification SHANTERIA D. DAVIS , hereby states that he /she is Vice President of JPMorp,an Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHANTERIA D. DAVIS Vice President Date: I • a$ -1 JPMor2an Chase Bank, N.A Borrowerc, 6k Property Address: I tH 3 11)004JA c� 1 (31'3 County: Last Four of Loan Number:S Ey,h i 6 i t A a j t t i ALL that certain tract of land with the improvements thereon erected situate in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Eastern dedicated right -of -way line of sixty (60) feet wide Northfield Drive at the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned subdivision plan; thence along said dividing line and through the party wall dividing the double dwelling erected on Lots Nos. 3 and 4 aforesaid, and beyond, South 66 degrees 47 minutes 53 seconds East, 123.01 feet to a point; thence along lands now or formerly of William Byers, and lands now or formerly of Oscar Lourdes at al and abutting the Western terminus of a certain unopened sixteen (16) feet wide alley as shown on the hereinafter mentioned subdivision Plan, South 02 degrees 16 minutes 00 seconds West, 59.97 feet to a point; thence along the dividing line between Lots Nos. 4 and 5 on said plan, North 57 degrees 00 minutes 13 seconds West, 149.23 feet to a point on the Eastern dedicated right -of -way line of Northfield Drive; thence along said right -of -way line by a curve to the left with a radius of 180.00 feet an arc distance of 30.77 feet to a point, the place of BEGINNING. BEING further described as Lot No. 4 of Plan 3 of Northfield prepared by Stephen G. Fisher, R.S., dated November 9, 1984 and recorded in Cumberland County Plan Book 47, Page 113, and being improved with a single family semi - attached dwelling known and numbered as 1043 Northfield Drive. i to be recorded �a'Ad County PA • - l ei �^��'"aa7+ / Recorder of Deeds OR # 80OPG251 l Eys,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5 -7734) CHASE � P.O. Box 44090 � Jacksonville, FL 32231 -4090 June 6, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00017084 HDLO ZB 15713 -BR860 LEON L GRICKIS JR 1043 NORTHFIELD DR CARLISLE, PA 17013 -1387 Act 91 Notice Account: _5535 (the "Loan") Property Address: 1043 NORTHFIELD DR CARLISLE, PA 17013 (the "Property") Dear LEON L GRICKIS JR: On the following page, you will fmd 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.) 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 TRADUCCION 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): LEON L GRICKIS JR LISA E OTTO PROPERTY ADDRESS: 1043 NORTHFIELD DR CARLISLE, PA 17013 LOAN ACCOUNT NUMBER: _5535 ORIGINAL LENDER: CHASE MANHATTAN MORTGAGE CORPORATION 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. YO U SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YO U HA VE A MEETING WITH COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY (3 0) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE 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 APPLICATION IS E VENTUALL Y APPRO VED 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 filed 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: 1043 NORTHFIELD DR, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 04/01/2012 $975.72 05/01/2012 $975.72 06/01 /2012 $975.72 07/01 /2012 $975.72 08/01/2012 $975.72 09/01/2012 $975.72 10/01/2012 $975.72 11/01/2012 $975.72 12/01 /2012 $975.72 01/01/2013 $975.72 02/01 /2013 $975.72 03/01/2013 $975.72 04/01 /2013 $975.72 05/01/2013 $975.72 06/01/2013 $975.72 Other charges: Late Charges: $156.64 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $450.58 Amount Held in Suspense: $667.98 TOTAL AMOUNT PAST DUE: $14,575.04 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 $14,575.04, 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 Sheriffs 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 Sheriff's 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 - 5004605 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 Deny Street Harrisburg 17104 Region Housing Alliance of York/Y Housina Resources 717 - 855 -2752 290 West Market Street York 17401 Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717 -334 -1518 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. BR860 Chase (FL5 -7734) CHASE i P.O. Box 44090 m Jacksonville, FL 32231 -4090 June 6, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00017085 HDLO ZB 15713 -BR860 LISA E OTTO 1043 NORTHFIELD DR CARLISLE, PA 17013 -1387 Act 91 Notice Account: _535 (the "Loan") Property Address: 1043 NORTHFIELD DR CARLISLE, PA 17013 (the "Property ") Dear LISA E OTTO: 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 Agencv. 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 Pennsvlvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons with impaired hearing can call 717- 780 - 1869.) 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 TRADUCCION 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): LEON L GRICKIS JR LISA E OTTO PROPERTY ADDRESS: 1043 NORTHFIELD DR CARLISLE, PA 17013 LOAN ACCOUNT NUMBER: _5535 ORIGINAL LENDER: CHASE MANHATTAN MORTGAGE CORPORATION 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 SHOULD FILE A HEMAP APPLICATION AS SOONAS POSSIBLE IF YOU HAVE A MEETING WITH COUNSELING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY (3 0) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE A CTION A GA INS T YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " YOU HAVE 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 APPLICATION IS E VENTUA LL Y A PPR 0 VED 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 filed 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: 1043 NORTHFIELD DR, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 04/01/2012 $975.72 05/01/2012 $975.72 06/01/2012 $975.72 07/01/2012 $975.72 08/01/2012 $975.72 09/01/2012 $975.72 10/01/2012 $975.72 11/01/2012 $975.72 12/01/2012 $975.72 01/01/2013 $975.72 02/01/2013 $975.72 03/01/2013 $975.72 04/01/2013 $975.72 05/01/2013 $975.72 06/01/2013 $975.72 Other charges: Late Charges: $156.64 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $450.58 Amount Held in Suspense: $667.98 TOTAL AMOUNT PAST DUE: $14,575.04 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 $14,575.04, 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 an tie 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 Sheriff's 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 - 5004605 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 - 334 -1518 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. BR860 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA rn -t JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE 1'j. S3U s� f MANHATTAN MORTGAGE CORP. Case No. Vi t -- Plaintiff VS. G ) rt LEON L. GRICKIS JR�� LISA OTTO Defendant(s) 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. Respectfully submitted: (Signature o Counsel for Plaintiff) Date 1-013 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDS141P 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: cl-ISTOMER/PRINIA III-' , .t pPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes Ej No E3 Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes D No ET ��— Mailing Address (if different): City: State: Zip: Phone Numbers: Rome; Office: Cell: Other: Email: # of people in household; Haw long? Mailing Address, City: State: Zip: Phone Numbers: Home: Office,: Cell: Other: Email: # ofpeople in household: How long? , :FINANCIAL [Nmiauvrm 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 &t Insurance: Date of Last Payment: l'ritr ary Reason for Default: Is the loan in Bankruptcy? Yes (j No If yes, provide rimes, location of court, Case number & attorney: _ Assets A mount Owed Value: Home: $ Other Real Estate: $ Retirement Funds: $ Investments: $ $ Checking; $� $ Savings; $ Other: $� $ Automobile fl: Model: Year: Amount owed: Value: Automobile #2 : Model: Yew: Amount owed: Value: Other transportation automobiles boats motore Iles .i Model. Year: Amount owed: Value Monthly Income Name of Employers: 1, 2. 3. Additional Income Description (not wages ): I . monthly amount: 1 monthly amount: Borrower Pay bays: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mo a Food 2 Mort a e Utilities Car Pa S-n s Condo/Neigh. Fees Auto Insurance Ivied. not covered Auto fuel/repairs Other prop, payment Install- Loan oan Pa mint Cable TV Child Stt rtlAlirn. Sponding Mane p3 ICFild CarelTuft, Other Expenses Amount Available for Monthly Mortgage Payments Based on l"ricome & Expenses: Have you been working with a Housing Counseling Agency"?' Yes El No El If yes, please provide the following infonnation: Counseling Agency: Couriselor: Phone.(Office): _ Fax: 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 tender or lender's loan servicing company to resolve your delinquency? Yes ( No Q if yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: -- authorize the above named to usetrefer this information to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. 1/'We understand that 11we am/are under no obligation to use the services provided by the above earned Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following informations to lender and lender's counsel: Proof of income Past Z bank statements Proof of arty expected income for the last 45 days '1 Cope of a current utility bill Letter explaining reason for delinquency and any supporting documentation . (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson T;; 1 1(_) Sheriff �rx of arolht Jody S Smith i"' ' 23H3 SEP 27 AM 10: Chief Deputy `C.LIMBERLAI'viCi COUNTY Richard W Stewart PENNSYLVANIA Solicitor ')Pr C � = JPMorgan Chase Bank, N.A. vs. Case Number Leon Lewis Grickis, Jr. (et al.) 2013-5368 SHERIFF'S RETURN OF SERVICE 09/14/2013 11:15 AM - Deputy Mark Conklin, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosur- by "personally" handing a true copy to a person representing themselves to be the II-fen.an o wit: Leon Lewis Grickis, Jr. at 1043 Northfield Drive, Carlisle Borough, Carlisle, PA 111 I M• "K CO IN, DEPUTY 09/17/2013 07:22 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be th- Defendant, to wit: Lisa Otto at 552 Second Street, Carlisle Borough, Carilsle, PA 17013. r SHALL, D =• " SHERIFF COST: $57.56 SO ANSWERS, September 24, 2013 RONO R ANDERSON, SHERIFF FORM 3 JP MoC1AN CHASE EANK,KR7toNA . ASSOCAAflON se C.NASE 410141E. : IN THE COURT OF COMMON PLEAS OF F4NgNCE 1_t.(; SCAM "(D CHASE : CUMBERLAND COUNTY,PENNSS ,V IIA MA■4-1AT1AN MCrrGACIE Cog f, -Plaintiff(s) rri x c,5 VS. • r -r- 1>C— • LEON 4_. C�124CKiS �� > tS q cm Defendant(s) �j l ej S CIVIL 2>-5 .c- ea REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 6N2U 'j 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure Diversion Program"and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Signatur of fendant's Counsel/Appointed Date //AV(-7 • Legal Representative ?r et 0. Sha 11 / (R.7/3 Signature of Defendant Date Signature of Defendant Date CERTIFICATE OF SERVICE I hereby certify that on November 12, 2013, I, Lauren McVaugh, secretary at Baric Scherer LLC, did serve a copy of the Request for Conciliation Conference, by first class U.S. mail, postage prepaid, to the person below: Alyk L. Oflazian KML Law Group, P.C. Suite 5000-BNY Mellon Independence Center 701 Market Street Philadelphia, Pennsylvania 19106 ' L ug Lauren McVaug JP MORGAN CHASE BANK : IN THE COURT OF COMMON PLEAS OF NATIONAL ASSOCIATIION SBM : CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN : c-, letit _ MORTGAGE CORP., w Plaintiff 3— 3(r,$ r u ms 7► =- z 1;'t;._ vs. CIVIL ACTION .`< a ;;'.7 r-- ---i c. <c--, xi. = NO. 13-5358 CIVIL ›.c-) zz 2',-- -x c) ..47.-- LEON L. GRICKIS JR. and LISA : c);` OTTO, : -` Defendants : - /,�CCASE MANAGEMENT ORDER 9_4 AND NOW, this /`�~"` day of November, 2013, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on ,4dA, /G(320/ , at a%3G, m in. Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss'and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, ✓ 6 Kevi, A. Hess, P.J. /Alyk L. Oflazianan, Esquire KML Law Group, P.C. Suite 5000-BNY Mellon Independence Ctr. 701 Market Street Philadelphia, PA 19106 For the Plaintiff ,./ ret Shaffer, Esquire 19 West South Street Carlisle, PA 17013 For the Defendants :rim C-3I ES Plat 1- �/ ol/3 JP MORGAN CHASE BANK • IN THE COURT OF COMMON PLEAS OF NATIONAL ASSOCIATIION SBM : CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN : MORTGAGE CORP., Plaintiff • • vs. • CIVIL ACTION • l3-53643 NO. - CIVIL LEON L. GRICKIS JR. and LISA • OTTO, • Defendants • ORDER AND NOW, this /o day of January, 2014, at the request of counsel for the parties, the conciliation conference set for January 10, 2014, is continued to Friday, March 7, 2014, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi . Hess, P. J. /Nathan C. Wolf, Esquire 10 E. High Street Carlisle, PA 17013 For the Plaintiff ./gCet Shaffer, Esquire 19 West South Street Carlisle, PA 17013 `n { For the Defendants c; :rlm � - L-L /oily JP MORGAN CHASE BANK : IN THE COURT OF COMMON PLEAS OF NATIONAL ASSOCIATIION SBM : CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC : SBM TO CHASE MANHATTAN : MORTGAGE CORP., • Plaintiff • vs. : CIVIL ACTION 13 -53C8 : LEON L. GRICKIS JR. and LISA : OTTO, • Defendants ORDER AND NOW, this 2.2 r day of January, 2014, the conciliation conference set for March 7, 2014, is continued to Friday, March 21, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, Key' A. Hess, P. J. - Nathan C. Wolf, Esquire 10 E. High Street ca , Carlisle, PA 17013 -- For the Plaintiff cr,* N Bret Shaffer, Esquire -C " N a 19 West South Street Carlisle, PA 17013 112 For the Defendants > -5! -t :rim tCfrf eS" JP MORGAN CHASE BANK : IN THE COURT OF COMMON PLEAS OF NATIONAL ASSOCIATIION SBM : CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC : SBM TO CHASE MANHATTAN : MORTGAGE CORP., Plaintiff VS. • • LEON L. GRICKIS JR. and LISA • OTTO, Defendants CIVIL ACTION I3-5(...0 8 NO. 3-CIVIL ORDER AND NOW, this day of March, 2014, following conciliation conference, this matter is again continued to give the defendants one final opportunity to submit materials which have been requested of them. Unless this matter is accepted for further review by the plaintiff on or before the close of business April 21, 2014, this matter will be removed from the Cumberland County Mortgage Foreclosure Diversion Program effective April 22, 2014, upon written request of local counsel for the plaintiff. Nathan C. Wolf, Esquire 10 W. High Street Carlisle, PA 17013 For the Plaintiff Bret Shaffer, Esquire 19 West South Street Carlisle, PA 17013 For the Defendants .37,9//Y Ces- BY THE COURT, Kevin Hess, P. J. JP MORGAN CHASE BANK . IN THE COURT OF COMMON PLEAS OF NATIONAL ASSOCIATIION SBM : CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC : SBM TO CHASE MANHATTAN : MORTGAGE CORP., Plaintiff vs. LEON L. GRICKIS JR. and LISA OTTO, Defendants CIVIL ACTION NO. 3-=53.58-eIL 13-53(08 ORDER AND NOW, this .24 day of May, 2014, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this matter is lifted. ..Nathan C. Wolf, Esquire 10 W. High Street Carlisle, PA 17013 For the Plaintiff Bret Shaffer, Esquire 19 West South Street Carlisle, PA 17013 For the Defendants :r1m Ccrai ES %n-al ls.L Sys/fit BY THE COURT, /frios4 Kevi . Hess, P. J. rs ro 3 _e- --H risco = m A r ri - --4 U1 --4C) Win. 3 In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT . THIS LAW 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. No. 13-5368 Enter the Judgment in favor of Plaintiff and against LEON L. GRICKIS JR. and LISA OTTO by default for want of an Answer. Assess damages as follows: $109,273.71 Debt Interest from 8/1/2013 to Date of Sale per diem at $5.58 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW By: KML LAW GR , P.C. Michael McKeeve a. 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. 205047 r2rf�,Jill P. Jenkins Pa. ID 306588 0/1(64 ✓ �U�V0 Andrew F. Gomall Pa. ID 92382��eV,V Attorneys for Plaintiff 1:\(‘ �� (9 , Judgment is entered in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. and against LEON L. GRICKIS JR. and LISA 01.110 by ult ft of an Answer and damages assessed in the sum of $109,273.71 as per the above certification. Prothonotary 1 Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 LEON L. GRICKIS JR. LISA OTTO (Mortgagors and Record Owner(s)) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff vs. Defendant(s) No. 13-5368 THIS LAW 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. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberl d County 1 Courthouse Square �1 Carlisle, PA 17013 Prothonotary sa 1 By: Deputy If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 123961FC THIS LAW 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. TO: LEON L. GRICKIS JR. GRICKIS JR., LEON L. 1043 Northfield Drive Carlisle, PA 17013 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle , PA 17013 Defendant(s) TO: LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 DATE OF THIS NOTICE: May 7, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-5368 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW G ' O P, ' .C. Michael M • eever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff THIS LAW 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. TO: LISA OTTO OTTO, LISA E. 1043 Northfield Drive Carlisle, PA 17013 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle , PA 17013 Defendant(s) TO: LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 DATE OF THIS NOTICE: May 7, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-5368 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 OFFLR 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 By: KML LA � G ; OUP, P.C. Mic 1 McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff THIS LAW 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. TO: LISA OTTO OTTO, LISA E. 552 Second Street Carlisle, PA 17013 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle , PA 17013 Defendant(s) TO: LISA OTTO 552 Second Street Carlisle, PA 17013 DATE OF THIS NOTICE: May 7, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-5368 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRII'IhN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW OUP, P.C. Michae y cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 A 1yk L. Oflazian Pa. ID 312912 VSalvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff THIS LAW 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. TO: Bret P. Shaffer, Esq BARIC SCHERER LLC 19 West South Street Carlisle, PA 17013 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle , PA 17013 Defendant(s) TO: Bret P. Shaffer, Esq 19 West South Street Carlisle, PA 17013 DATE OF THIS NOTICE: May 7, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-5368 JMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: 'LI KML LAW i%O P, P.C. Michael 'v., cKeever Pa. ID 56129 Lisa Lee ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 JSalvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Defendant(s) NO. 13-5368 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): LEON L. GRICKIS JR., has a last known residence of 1043 Northfield Drive, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authopes. Date By: KML LAW GRO, P. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 2Al1 P. Jenkins Pa. ID 306588 yk L. Oflazian Pa. ID 312912 ennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff AA}, Department of Defense Manpower Data Center Results as of : May -21-2014 09:31:48 AM SCRA 3.0 Status Report Pursuant to Service -members Civil Relief Act Last Name: GRICKIS First Name: LEON Middle Name: L. Active Duty Status As Of: May -21-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No , NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .. ' No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or Hisi-ter Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. YJL Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 -1:410N- 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/PCO9SLDR.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: Z91DGE2F2066R80 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Defendant(s) NO. 13-5368 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): LISA OTTO, has a last known residence of 552 Second Street, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to autho `es. ela y: KML LAW (Its ', P.C. Michael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 1yk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Date .f Z/ '1/0l B Department of Defense Manpower Data Center Results as of : May -21-2014 09:33:39 AM SCRA 3.0 Status Report Pursuant to Sery ce terbers Civil Relief Act Last Name: OTTO First Name: LISA Middle Name: Active Duty Status As Of: May -21-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ! No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HisfHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. r�. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.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: Q9503E1 F006F3F0 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record owner(s)) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5368 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., and against LEON L. GRICKIS JR. and LISA OTTO for failure to file an Answer in the above action within (20) days from the date of service of the Complaint, in the sum of $109,273.71. By: KML LAWR�UP, P.C. Michael McKe v r 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. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 orney for P1 ' ti p�� 6� I herebycertifythat the above names are correct and t t eci e residence address ss of the judgment creditor is P J g JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 and that the name(s) and last known address(es) of the Defendant(s) is/are LEON L. GRICKIS JR., 1043 Northfield Drive Carlisle, PA 17013 and LISA OTTO, 552 Second Street Carlisle, PA 17013;(x9. By: i KML LA GROUP, P.C. Michael cKeever 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. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff —11-604 Fretidte 3161 [� ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 03/01/2012 through 07/31/2013 Reasonable Attorney's Fee Late Charges Escrow Advance BPO/Appraisals Property Inspections Suspense Balance Property Preservation AND NOW, this 13-5368/123961FC day of By: $101,751.36 $2,883.03 $1,650.00 $156.64 $3,022.08 $250.00 $158.58 ($667.98) $70.00 $109,273.71 KML LAW GRO 1 Michael McKeever 'a. ID 56129 Jay E. Kivitz Pa. I ! 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. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 A"orneys fo Plaintiff J 3 Abe o , 2014 damages 4fikassess . as ab Pro Prothy • PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff tBERL — b PEFNHS YLIDAQLI`� A JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5368 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 8/1/2013 to Date of Sale per diem at $5.58 (Costs to be added) @jai- JiW sope / a e 5-7 6- co 103,7s- 6 . 1"--o X46.3 / Pd /94� e/c-74E-U962>1 1/Uti,��3ol�ag/ of- g_aized By: $109,273.71 y(gw KML LA GO P, P.C. Michael Mc -ever 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. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 IR4r Attorneys for Plaintiff rts bue RML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO (Mortgagor(s) and Record Owner(s)) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) ,<< 3 CUI1BE Pc j/R ` -t r�i�fl,,CO�(,' LL IN THE COUR`"I�IMuN PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 13-5368 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1043 Northfield Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 LISA OTTO 552 Second Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 LISA OTTO 552 Second Street Carlisle, PA 17013 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1043 Northfield Drive Carlisle , PA 17013 BARIC SCHERER LLC 19 West South Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my 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. DATED: Slz1/ze)/,f By: KML L W GROUP, P.C. Michael 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. 205047 Aill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff jfelq0� fcati,e 316(60 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendants 20/111;i1 Y 23 A1111: CUMBERLAND COU IA 13-5368 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5368 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GRICKIS JR., LEON L. LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 Your house at 1043 Northfield Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $109,273.71 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 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: 13-5368 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 pf the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://wwwphiladelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 13-5368 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.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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@kmllawgroup.com.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 123961FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff J r� 3 All II: : CUj` L' ER 4tio C 13-5368 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE IN THE COURT OF COMMON PLEAS LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5368 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: OTTO, LISA E. LISA OTTO 552 Second Street Carlisle, PA 17013 Your house at 1043 Northfield Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $109,273.71 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: c 13-5368 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 c 13-5368 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.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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@kmllawgroup.com.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 123961FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMorgan Chase Bank, National Association Vs. NO 13-5368 Civil Term CIVIL ACTION — LAW Leon L. Grickis, Jr. Lisa Otto WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $109,273.71 L.L.: $.50 Interest from 8/1/2013 to Date of Sale per diem at $5.58 Atty's Comm: Due Prothy: $2.25 Atty Paid: $206.31 Other Costs: Plaintiff Paid: Date: 5/23/2014 (Seal) REQUESTING PARTY: Name: Jennifer Frechie, Esquire Address: KML Law Group, P.C. 701 Market Street Ste. 5000 Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 866-413-2311 Supreme Court ID No. 316160 David D. uell, Prothdnotary By: Deputy KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff . rilE PROTWON07t'ir 2014 AUG 18 AM 18, 23 CUMBERLAND COUNTY PE NSYLVA�� IN nit COURT OF COMMON PLEAS JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5368 Book: Writ: NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for September 03, 2014 at 10:00 AM in the above matter has been continued until October 01, 2014 at 10:00 Date: By: LAW GROUP, P.C. 1 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Michael McKeever Pa. ID 56129 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 �ennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF FILING Term No. 13-5368 Book: Writ: I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of Continued Sheriff's Sale in the above upon the following parties on the date listed below: LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 defendant(s) SHERIFF OF CUMBERLAND COUNTY Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 (via facsimile or e-mail) PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 (via a -filing if applicable) Date: By: (/) laiLV 11)44j, KML LAW GROUP, P 701 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Genevieve Mautz KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Plaintiff Defendant(s) OFfu 47111 sEp 7 CumppRt.,, PENNSh 2: 123961FC CF: 09/11/2013 SD: 10/01/2014 $109,273.71 COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-5368 Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. y submizec • Re ec BY: Andrew Hauck Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP.; et seq. Plaintiff (Petitioner) V. LEON L. GRICKIS JR.; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13-5368 Sheriffs Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint 0 Summons © Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served LEON L. GRICKIS JR the above process on the 6 day of August, 2014, at 1:34 o'clock, PM, at 1043 NORTHFIELD DRIVE CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: a By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residencebecause no adult family member was found • By banding a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides • By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s) agent or to the person for the time being in - : charge thereof • • Name: ROSE MIRIELLO Relationship/Title/Position: Co -Habitant Remarks: Description: Approximate Age 41-43 Height 5'4 Weight 125. Race WHITE Sex FEMALE Hair BROWN Military Status: El No ❑ Yes Branch: Commonwcalth/State of County of ) SS: Before me, the, undersigned notary public, this day, personally, appeared duly,swor,o according to law, deposes the following: % wt.. C to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct (Signature of Affiant) Fjie.Numberl23961FC Case ID #:4654668 CONW ALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflarbach, Notary Public Washington Township, Barks County MyCoornrni_sion^xpires P ove`er 18, 2017 Notary Public UNITED STATES POSTAL SERVICE Date: July 4, 2014 kalilah osei: The following is in response to your July 4, 2014 request for delivery information on your Certified MaiITM item number 9171999991703406806497. The delivery record shows that this item was delivered on June 16, 2014 at 3:43 pm in CARLISLE, PA 17013. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : 6 2ii\J Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service Name and Address of Sender OLDBECK(If iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: Certified ❑Recorded Delivery (International) CI CI ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here issued as a certificate of mailing, or for additional copies of this bill) Postmark and a Date of Receipt Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 TENANTS/OCCUPANTS 1043 Northfield Drive 2. PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Carlisle' PA /013 BARIC SCHERER 19 West South Street Carlisle. PA 17013 _LC 3. -...,. Harrisburg, PA 17105-2675 / -1\Att•t: 4.• --Y `c. / — n 0l3, tibitG 'e8 �` ,980 2074 ft , I 6.-='' 7. 8. TotalNumber Piece Listed by Sender ti TotalNumber of Piece Received at Post O is Postmaster, Per (N receiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen 123961 FC Cumberland County Sale Date: 09/03/2014 LEON L. GRICKIS JR. & LISA OTTO 50A3 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-5368 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1043 Northfield Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1043 Northfield Drive Carlisle , PA 17013 BARIC SCHERER LLC 19 West South Street Carlisle, PA 17013 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. DATED: September 15, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant KML Law Group, P.C. By: David Fein, Esquire Attorney I.D. # 82628 Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM" TOCHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County No. 13-5368 PLAINTIFF'S PETITION TO SET ASIDE SHERIFF'S SALE Plaintiff, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP., ("Plaintiff'), petitions this Honorable Court to set aside the Sheriffs Sale of the subjectproperty, held on October 01, 2014, and assigns the following reasons therefore: 1. Plaintiffs Complaint in Mortgage Foreclosure was filed on September 11, 2013. 2. The property is located at 1043 Northfield Drive, Carlisle, PA 17013 ("Property"). 3. On May 23, 2014, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants, in the amount of $109,273.71, plus costs, based upon the demand in Plaintiffs Complaint. 4. A Sheriffs Sale was held on October 1, 2014 at or after 10:00 a:m. 5. Subsequent to the sale it was discovered that Defendant Leon L. Grickis, Jr. filed a Chapter 13 Bankruptcy Petition in the Middle District of Pennsylvania, Docket number 14-04568 at 8:33 a.m. on October 1, 2014 but failed to promptly notify the Sheriff or Plaintiff.. A true and correct copy of the time -stamped bankruptcy petition is attached hereto and marked as Exhibit "A". 6. The Sheriffs Sale is void as a matter of law. 7. In addition to the reasons dated above, the Court should grant the equitable relief requested for the following reasons: a). the requested relief is specifically authorized by Rule 3132 of the Rules of Civil Procedures; b). the sheriff has not yet delivered the deed; 8. Plaintiff therefore requests that the Sheriffs Sale of the Property be set aside due to the bankruptcy filing of Defendant Leon L. Grickis, Jr. _ WHEREFORE, Plaintiff prays that the Court enter the attached Order setting aside and ordering a new Sheriffs Sale. Respectfully submitted, David Fein, Esquire Attorney for Plaintiff KML Law Group, P.C. By: David Fein, Esquire Attorney I.D. # 82628 Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 LEON L. GRICKIS JR. LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 vs. VERIFICATION In the Court of Common Pleas of Cumberland County No. 13-5368 The undersigned is the attorney for Plaintiff in this Action and I hereby verify that all of the facts set forth in the attached petition to set aside Sheriffs Sale are true and correct to the best of my information and belief. I understand that the foregoing statements are made subject to the penalties of 18 Pa.C.S.A. § 4904. David Fein, Esquire Attorney for Plaintiff KML Law Group, P.C.... By: David Fein, Esquire Attorney I.D. # 82628 Suite 5000 – BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County MEMORANDUM OF LAW NO. 13-5368 Pursuant to Federal law, the filing of a Petition for relief under the United States Bankruptcy Code operates as a stay of all proceedings. See, 11 US Code 362: (a) Except as provided in subsection (b) of this section, a petition filed under section 301, 302, or 303 of this title, or an application filed under section 5(a)(3) of the Securities Investor Protection Act of 1970, operates as a stay, applicable to all entities, of— (1) the commencement or continuation, including the issuance or employment of process, of a judicial, administrative, or other action or proceeding against the debtor that was or could have been commenced before the commencement of the case under this title, or to recover a claim against the debtor that arose before the commencement of the case under this title; (2) the enforcement, against the debtor or against property of the estate, of a judgment obtained before the commencement of the case under this title; Further Pa. R.C.P. 3132 provides as follows: Upon petition of any part in interest before delivery of the personal property or of The sheriffs deed to real property, the court may, upon proper cause shown, set aside the sale and order a resale or enter any other order which may be just and proper under the circumstances. CONCLUSION For all the reasons discussed above and in the attached Petition to Set Aside Sheriffs Sale, the Court should grant the requested relief and enter the attached proposed order. Respectfully submitted, David Fein, Esquire Attorney for Plaintiff EXH:1T" 131 (Official Form I) (04/13 UNITED STATES BANKRUPTCY COURT VOLUNTARY PETITION Name of Debtor (if idividual, enter Last, First, Middle): G ¢.‘Ci 33'42- Le -o,, Let.-) .s Name of Joint Debtor (Spouse) (Last, First, Middle): All Other Names used by the Debtor in the last 8 years (include married, maiden, and trade names): All Other Names used by the Joint Debtor in the last 8 years (include married, maiden, and trade names): Last four digits of Soc. Sec. or Individual -Taxpayer I.D. (ITIN)/Complete EIN (if more than one, state all): OS5 Last four digits of Soc. Sec. or Individual -Taxpayer I.D. (1TIN)/Complete EIN (if more than one, state all): Street Address of Debtor (No. and Street, City, and State): 1 O u3 0 ca-`1riNceld )jeio Cs.12-lse, P( `1-1(4`3 Street Address of Joint Debtor (No. and Street, City, and State): IZIPCODE I (ZIP CODE I County of Residence or of the Princip l Place Qf Busin C -U -r t) .hd LL \Q County of Residence or of the Principal Place of Business: Mailing Address of Debtor (if different from street address): Mailing Address of Joint Debtor (if different from street address): ZIP CODE IZIP CODE I Location of Principal Assets of Business Debtor (if different from street address above): IZIP CODE I Type of Debtor (Form of Organization) (Check one box.) lie Individual (includes Joint Debtors) See Exhibit Don page 2 of this form. ❑ Corporation (includes LLC and LLP) ❑ Partnership IN Other (If debtor is not one of the above entities, check this box and state type of entity below.) Nature of Business (Check one box.) ■ Health Care Business ❑ Single Asset Real Estate as defined in 11 U.S.C. § 101(51B) 0 Railroad ❑ Stockbroker ■ Commodity Broker ❑ Clearing Bank ❑ Other Chapter of Bankruptcy Code Under Which the Petition is Filed (Check one box.) ■ Chapter 7 0 Chapter 15 Petition for ❑ Chapter 9 Recognition of a Foreign 0 Chapter II Main Proceeding ❑ Chapter 12 0 Chapter 15 Petition for Chapter 13 Recognition of a Foreign Nonmain Proceeding Chapter 15 Debtors Country of debtor's center of main interests: Each country in which a foreign proceeding by, regarding, or against debtor is pending: Tax -Exempt Entity (Check box, if applicable.) 0 Debtor is a tax-exempt organization under title 26 of the United States Code (the Internal Revenue Code). Nature of Debts (Check one box.) LC' Debts are primarily consumer 0 Debts are debts, defined in 11 U.S.C. primarily § 101(8) as "incurred by an business debts. individual primarily for a personal, family, or household purpose." Filing Fee (Check one box.) ❑ Full Filing Fee attached. Er Filing Fee to be paid in installments (applicable to individuals only). Must attach signed application for the court's consideration certifying that the debtor is unable to pay fee except in installments. Rule 1006(b). See Official Form 3A. ❑ Filing Fee waiver requested (applicable to chapter 7 individuals only). Must attach signed application for the court's consideration. See Official Form 3B. Chapter 11 Debtors -- Check one box: • Debtor is a small business debtor as defined in II U.S.C. § 101(510). ❑ Debtor is not a small business debtor as defined in 1I U.S.C. § 101(51D). Check if: El Debtor's aggregate noncontingent liquidated debts (excluding debts owed to insiders or affiliates) are less than $2,490,925 (amount subject to adjustment on 4/01/16 and every three years thereafter). Check all applicable boxes: IN A plan is being filed with this petition. ■ Acceptances of the plan were solicited prepetition from one or more classes of creditors, in accordance with 11 U.S.C. § 1 126(b). Statistical/Administrative Information ( ❑ Debtor estimates that funds will be available for distribution to unsecured creditors.r ❑ Debtor estimates that, after any exempt property is excluded and administrative expenses paid, there will be no funds available fo,* distribution to unsecured creditors. THIS SPACE IS FOR COURT USE ONLY s r b Es 'mated Number of Creditorst5 0 0 0 0 ❑ ❑ ❑ 0 ❑> I-49 50-99 100-199 200-999 1,000- 5,001- 10,001- 25,001- 50,001- OveiiC 5,000 10,000 25,000 50,000 100,000 l0(c) _ c D n : -11 Estimated Assets -0 f El 0' iii ❑ ❑ ❑ ❑ ❑ -.t �7'; sot. $50,001 to $100,001 to $500,001 $1,000,001 $10,000,001 $50,000,001 $100,000,001 $500,000,001 Md�i2han 550,000 $100,000 $500,000 to $1 to $10 to $50 to $ 100 to $500 to $1 billion $1 -C an million million million million million n ' rn 4 CD CI CO Estimated Liabilities O • 0 Q( in 0 0 0 0 0 Elw SO to $50,001 to $100,001 to $500,001 $1,000,001 $10,000,001 $50,000,001 $100,000,001 $500,000,001 Moteihan $50,000 $100,000 $500,000 to $1 to $ l0 to $50 to $100 to $500 to $ l billion $1 billion ' million million million million million W >: BI (Official Form I) (04/13) Pane 2 Voluntary Petition (This page must be completed and filed in every case.) v Name of Debtor(s): -. All Prior Bankruptcy Cases Filed Within Last 8 Years (If more than two, attach additional. sheet.) Location Where Filed: Case Number: { Date Filed: Location Where Filed: Case Number: Date Filed: Pending Bankruptcy Case Filed by any Spouse, Partner, or Affiliate of this Debtor (If more than one, attach additional sheet.) Name of Debtor: Case Number. Date Filed: District Relationship: Judge: Exhibit A (To be completed if debtor is required to file periodic reports (e.g., forms 10K and 10Q) with the Securities and Exchange Commission pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 and is requesting relief under chapter I I.) ❑ Exhibit A is attached and made a part of this petition. Exhibit B (To be completed if debtor is an individual whose debts arc primarily consumer debts.) I, the attorney for the petitioner named in the foregoing petition, declare that I have informed the petitioner that [he or she) may proceed under chapter 7, 11, 12, or 13 of title 11, United States Code, and have explained the relief available under each such chapter. 1 further certify that I have delivered to the debtor the notice required by II U.S.C. § 342(b). X Signature of Attorney for Debtor(s) (Date) Exhibit C Does the debtor own or have possession of any property that poses or is alleged to pose a threat of imminent and identifiable harm to public health or safety? ❑ Yes, and Exhibit C is attached and made a part of this petition. Of No. Exhibit D (To be completed by every individual debtor. If a joint petition is filed, each spouse must complete and attach a separate Exhibit D.) ❑ Exhibit D, completed and signed by the debtor, is attached and made a part of this petition. If this is a joint petition: ❑ Exhibit D, also completed and signed by the joint debtor, is attached and made a part of this petition. Information Regarding the Debtor - Venue (Check any applicable box.) riir Debtor has been domiciled or has had a residence, principal place of business, or principal assets in this District for I80 days immediately preceding the date of this petition or for a longer part of such 180 days than in any other District. ❑ There is a bankruptcy case concerning debtor's affiliate, general partner, or partnership pending in this District. 0 Debtor is a debtor in a foreign proceeding and has its principal place of business or principal assets in the United States in this District, or has no principal place of business or assets in the United States but is a defendant in an action or proceeding [in a federal or state court] in this District, or the interests of the parties will be served in regard to the relief sought in this District. Certification by a Debtor Who Resides (Check all applicable ❑ Landlord has a judgment against the debtor for possession of debtor's ❑ Debtor claims that under applicable nonbankruptcy law, there are entire monetary default that gave rise to the judgment for possession, ❑ Debtor has included with this petition the deposit with the court of of the petition. Debtor certifies that he/she has served the Landlord with this certification. as a Tenant of Residential Property boxes.) residence. (lf box checked, complete the following.) (Name of landlord that obtained judgment) (Address of landlord) circumstances under which the debtor would be permitted to cure the after the judgment for possession was entered, and any rent that would become due during the 30 -day period after the filing (I 1 U.S.C. § 362(1)). B1 (Official Fenn 1) (04/13 Voluntary Petition {7Ris page must be completed and filed in ev ry case.) Name of Debtor(s): _ _ _ __-__Signatures - Signature(s) of Uebtor(s) (IndividualJoint) 1 declare under penalty of perjury that the information provided in this petition is true and correct. (If petitioner is an individual whose debts are primarily consumer debts and has chosen to file under chapter 7] I am aware that I may proceed under chapter 7, 11, 12 or 13 of title I I, United States Code, understand the relief available under each such chapter, and choose to proceed under chapter 7. [If no attorney represents me and no bankruptcy petition preparer signs the petition] 1 have obtained and read the notice required by 11 U.S.C. § 342(b). 1 request relief in accordance with the chapte • of title 11, United States Code, specified in this petition. X '�.. r Signature of a Foreign Representative I declare under penalty of perjury that the information provided in this petition is true and correct, that I am the foreign representative of a debtor in a foreign proceeding, and that I am authorized to file this petition. (Check only one box.) 0 I request relief in accordance with chapter 15 of title 11, United States Code. Certified copies of the documents required by I 1 U.S.C. § 1515 are attached. 0 Pursuant to 11 U.S.C. § 1511, I request relief in accordance with the chapter of title 11 specified in is petition. A certified copy of the order granting recognition of foreign main proceeding is attached. X Signature of Debtor X (Signature of Foreign Rep Signature of Joint Debtor +-rtt`1-is-LlB-05rla (Printed Name of Foreign R tire) Telephone Number (if not represented by attorney) 10-1— tt-le Date Date Signature of X Attorney* 1 , •1 V Signature of Non -Attorney Bankruptcy Petition Preparer I declare under penalty of perjury that: (1) 1 am a bankruptcy petition preparer as defined in 11 U.S.C. § 110; (2) I prepared this document for compensation and have provided the debtor with a copy of this document and the notices and information required under I I U.S.C. §§ 110(b), 110(h), and 342(b); and, (3) if rules or guidelines have been promulgated pursuant to 11 U.S.C. § 110(h) setting a maximum fee for services chargeable by bankruptcy petition preparers, I have given the debtor notice of the maximum amount before preparing any document for filing for a debtor or accepting any fee from the d btor, as required in that section. Official Form 19 is attached. Signature of Attorney for Debtors) Printed Name of Attorney for Debtor(s) t Firm Name Address Telephone Number Printed Name and ti if y of pt cy Petition Preparer Date 'In a case in which § 707(bX4)(D) applies, this signature also constitutes a certification that the attorney has no knowledge after an inquiry that the information in the schedules is incorrect Social -Security number (If the bankruptcy petition prcparer is not an individual, state the Social -Security number of the officer, principal, responsible person or partner of the bankruptcy petition preparer.) (Required by II U.S.C. § 110.) Signature of Debtor (Corporation/Partnership) 1 declare under penalty of perjury that the information provided in this petition is true and correct, and that I have been authorized to file this petition on behalf of the debtor. The debtor requests the relief in accordance with the chapter of title 11, United States Code, specified in this petition. X Address X Signature Date „_ Signature of bankruptcy petition preparer or officer, principal, responsible person, or partner whose Social -Security number is provided above. Names and Social -Security numbers of all other individuals who prepared or assisted in preparing this document unless the bankruptcy petition preparer is not an individual. kf more than one person prepared this document, attach additional sheets conforming to the appropriate official form for each person. A bankruptcy petition preparer's failure to comply with the provisions of title 11 and the Federal Rules of Bankruptcy Procedure may result in fines or imprisonment or both. 1/U.S.C. §110: IXUSC•§'156. Signature of Authorized Ind c\••• Printed Name of Authorized Individual Title of Authorized Individual Date KML Law Group, P.C. By: David Fein, Esquire Attorney I.D. # 82628 Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CERTIFICATE OF SERVICE No. 13-5368 I, Jaclyn Jamieson, legal assistant for Plaintiff, do hereby certify that true and correct copies of the foregoing Petition to Set Aside Sheriffs Sale and all supporting papers hereto upon: LEON L. GRICKIS JR. 1043 Northfield Drive Carlisle, PA 17013 LISA OTTO 1043 Northfield Drive Carlisle, PA 17013 SHERIFF OF CUMBERLAND COUNTY Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 via first class mail, postage prepaid, on this 61 day of tee, , 2014. Jo Legal Assistant for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBM CHASE HOME. FINANCE LLC SBM TO CHASE MANHATTAN MORTGAGE CORP. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. LEON L. GRICKIS JR. LISA OTTO Mortgagor(s) and Record Owner(s) 1043 Northfield Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS RULE TO SHOW CAUSE of Cumberland County No. 13-5368 AND NOW, this /Z' day of C/�,„✓ a7 , 2015, upon consideration of the foregoing Petition to Set Aside the Sale of Plaintiff, it is hereby ordered that: 1. A rule is issued upon the Respondents to show cause why the Petitioner is not entitled to the relief requested; 2. Any Respondent who opposed the requested relief shall file an Answer to the Petition within twenty (20) days of the date of this Order; 3. The Petition shall be decided under Pa.R.C.P. 206.7 5. Argument shall be held on the / a o s .ae; day of c/�,0u S //%3C44 ,20.1<in Courtroom No. ( , of the Cumberland County Courthouse, i';vil, Pennsylvania; 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner; 7. The Sheriff shall not execute or deliver any deed to the execution premises pending further Order of Court. BY THE COURT: J.