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Home My WebLink About13-5663 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County 3 <I n 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 a ers 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's Name: JPMorgan Chase Bank, Lead Defendant's Name: Craig E. Harry C National Association T Dollar Amount Requested: El within arbitration limits I Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander /Libel/Defamation ❑ Employment Dispute: Other El Zoning Board C ❑ Other: T ❑ Other: I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS B ❑ Toxic Waste ❑ Ejectment F1 Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 t � SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530, AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 rri «' KING OF PRUSSIA, PA 19406'' TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 043868' JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS =x:r PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY i c ' Vs. NO: Craig E. Harry 5 Forest Avenue Marysville, PA 17053 ; DEFENDANT COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. om �a� Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. a 4 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13 -043 868 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: Craig E. Harry 5 Forest Avenue Marysville, PA 17053 DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, JPMorgan Chase Bank, National Association, the address of which is, 3415 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee Mortgage Electronic Registration Systems, Inc., as nominee for First National Bank of Chester County Thru AM Home Bank Division, its successors and assigns Mortgagor(s) Craig E. Harry (b) Date of Mortgage October 28, 2009 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Document ID# 200937336 Date: November 4, 2009 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for First National Bank of Chester County Thru AM Home Bank Division, its successors and assigns Assignee: JPMorgan Chase Bank, National Association Date of Assignment: June 10, 2013 Recording Date: June 18, 2013 Instrument No.: 201319850 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property which is subject to the Mortgage is generally known as 5 Forest Avenue, Marysville, PA 17053 and is more specifically described as attached as part of Exhibit "A ". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as Exhibit "B ". 5. The name and mailing address of the Defendant is: Craig E. Harry, 5 Forest Avenue, Marysville, PA 17053. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of March 1, 2013 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of August 12, 2013: Principal Balance Due $111,843.97 Interest Currently Due and Owing at 5% $2,796.12 From February 1, 2013 through July 31, 2013 Late Charges $174.30 Escrow Advances $1,122.80 Property Inspection $14.00 TOTAL $115,951.19 9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible under the Note and Mortgage. 10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ". 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: 2 BY: Att rn ys for Pain f S & D File No. 13- 043868 N�i PREPARED BY: FIRST NATIONAL BANK OF CHESTER COUNTY aaa50 THRU AM HOME BANK DIVISION 3840 HEMPLAND ROAD, MOUNTVILLE, PA 17554 RECORD AND RETURN TO FIRST NATIONAL BANK OF CHESTER COUNTY THRU AM HOME BANK DIVISION 3840 HEMPLAND ROAD MOUNTVILLE, PA 17554 ATTN: FINAL DOCUMENTS Parcel ID # /UPI N: 09113002012 c E rest !}tee" +ynwu.py t 1 53 [Space Above This Line For Recording Dotal Commonwealth of Pennsylvania MORTGAGE FHA Case No. Mil Loan ID THIS MORTGAGE ( "Security Instrument ") is given on October 28th, 2009 The Mortgagor is CRAIG E. HARRY, MARRIED MAN ( "Borrower'). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ( "MERS "), (solely as nominee for bender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MFRS is organized and existing under the laws of Delaware, and has an address and telephone number of3300 S.W. 34th Avenue, Suite 101, Ocala, FL 34474 and P.O. Box 2026, Flint, Michigan 48501 -2026, tel. (888) 679 - MFRS. FIRST NATIONAL BANK OF CHESTER COUNTY THRU AM HOME BANK DIVISION ( "Lender ") is organized and existing under the laws of and has an address of 3840 HEMPLAND ROAD, MOUNTVILLE, PA 17554 . Borrower owes Lender the principal sum of One Hundred Seventeen Thousand Eight Hundred Twenty Six and no /100- - - - - - - - - - - - Dollars (U.S. $117, 826.00 ) - This debt is evidenced by Borrower's note dated the same date as this Security Instrument ( "Note'), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on November 1st, 2039 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect die security of this Security Instrument; and (c) die performance of Borrower's covenants and agreements under this Security Instrument and die Note. For this purpose, Borrower does hereby mortgage, grant and convey to MFRS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MFRS, die following described property located in CUMBERLAND County, Pennsylvania: I Initials FHA PejuiVylvania Mortgage with MFRS - 4196 Amended 6/02 PAFMMI - 03062009 Page I of 9 Nvi"v.ProClosc.com T Loan ID , SEE ATTACKED LEGAL DESCRIPTION. I I i I which has the address of 5 FOREST AVENUE, MAR'YSVILLE , [Street] [City] Pennsylvania 17053 ( " Property Address "); [Zip Codel TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS, (as nominee for Lender and Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due die principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ( "Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for die monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are ca ed "Escrow Funds." Initials: FHA Pennsylvania. Mortgage with MERS - 4196 Amended 6102 PATMM2 - 03062009 Page 2 of 9 www.ProClose.com Loan ID #' Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ( "RESPA "), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up die shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender die full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to die Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of die Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as follows; First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Tlard to interest due under tie Note; Fourth to amortization of tie principal of die Note; and EM , to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on die Property, whether now in existence or subsequently erected, against loss by floods to die extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of die proceeds to tie principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change die amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes die indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. S. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale, or transfer of die Property) and shall continue to occupy the Property as Borrower's principal residencgrfp r ast Initials `( RIA Pennsylvania Mortgage witli MFRS - 4196 Amended 6102 PA1TMM3 - 03062009 Page 3 of 9 www.ProClose.com Loan SD # one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of die Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of die full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to die entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations -on time directly to the entity wlhich is owed the payment. If failure to pay would adversely i affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument i Initials: FHA Pennsylvania Mortgage with MFRS - 4196 Amended 6102 PAFMM4 - 03062009 Page 4 of 9 www.ProClosemnn I I Loan ID (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn -St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j -3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if: (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to i subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of afiv right or remedy. Initials: I HA Eeimsylvania Mortgnge with MERS - 4196 Amended 6102 PAFMM5 - 03062009 Page 5 of 9 www.ProClosexont • t • Loan ID # 12. Successors and Assigns Bound; Joint and Several Liability; Co- Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co -signs this Security Instrument but does not execute the Note: (a) is co- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable Iaw requires use of another method. The notice shall be directed to die Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Lave; Severability. This Security Instrument shall be governed by Federal law and the law of die jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without die conflicting provision. To this end tie provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of die Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit die presence, use, disposal, storage, or release of any Hazardous Substances on or in die Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on die Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting die Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and die following substances; gasoline, kerosene, other flammable or toxic petroleuin products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where die Property is located that relate to health, safety or environmental protection. NON - UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for addi ' nal security only. Initials FHA Peimsylvania Mortgage witL MGRS - 4196 Amended 6/02 PA -T M6 - 03062009 Page 6 of 9 www.ProClose.com Loan ID # If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires Immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ( "Act ") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument, 22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)] ❑ Condominium Rider ❑ Growing Equity Rider ❑ Other [specify] ❑ Planned Unit Development Rider ❑ Graduated Payment Rider This is a contract under seal and may be enforced under 42 PA C.S. Section 5529(b). Initials: RIA Penmsylvania Mortgage with MFRS - 4196 Amended 6102 POMM7 - 03062009 Page 7 of 9 NnmProClose.com J Y Loan ID # BY SIGNING BELOW, Borrower accepts and agrees to th terms contain this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: _ (Seal) CRAIG E. HAR Borrower (Seal) Borrower (Seal) - Borrower (Seal) - Borrower (Seal) Borrower (Seal) Borrower COMMONWEALTH OF PA YORK County ss: On this, 28th day of October, 2009 , before me, the undersigned officer, personally appeared CRAIG 9. HARRY known to me (or satisfactorily proven) to be the person(s) whose name(s) is /are subscribed to the within instrument and acknowledged that he /she /they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commiss Expires CON1t ".Oh �E-- �uYI- UAPS4A rl yoik Cous�tY ilt i1itr >� " 1 � 15� 2010 Mom�'�ritF}c�lh�l�l�`� i�tldit of tdo4zdes 4qAM Title of Officer MIA Pemiglvattia Mortgage with MFRS - 4196 Amended 6102 PAFMM8 - 03062009 Page 8 of 9 inmProClose.cont Loan ID # Certificate of Residence I do certify that the correct address of the within -named mortgagee is 3840 HEMPLAND ROAD, MOUNTVILLE, PA 17554 Witness my hand this 28th day of October, 2009 HOMESALE SETTLEMENT SERVICES Agent of Mortgagee Initials: FRA PesuLVIvmila Mortgage with MERS - 4196 Amended 6102 PATMM9 - 03062009 Page 9 of 9 wwnv.ProClosexom v Exhibit "A" File No. ALL THAT CERTAIN tract of land together with the improvements thereon erected, situate in Overview, East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point, which point is the northeast corner of Forest Avenue and North Second Street; thence Eastwardly along the northern side of North Second Street, thirty - five and four tenths (35.4) feet to a point; thence Northwardly and for part of the distance through the partition wall of a double two and one -half (2 /z) story frame dwelling and beyond, one hundred fifty -three and three tenths (153.3) feet to a stake; thence Westwardly forty -four and five tenths (44.5) feet to Forest Avenue; thence Southwardly along Forest Avenue, one hundred fifty -six and two tenths (156.2) feet to the point of BEGINNING. HAVING thereon erected, a two and one -half (2 1 /2) story frame house which was unnumbered but is now numbered 5 Forest Avenue, Marysville, PA 17053. BEING Lot No.115 and the eastern part of Lot No. 114 on the plan of lots known as Overview East recorded in the Recorder's Office of Carlisle, Pennsylvania in Plan Book 1, Page 53. BEING THE SAME PREMISES which W.E.B. CONTRACTING, INC., A PENNSYLVANIA CORPORATION by Deed dated 1 O f ?,$ 1C't and intended for immediate recording in the Off lee of the Recorder of Deeds in and for Cumberland, Pennsylvania, granted and conveyed unto CRAIG E. HARRY, ADULT INDIVIDUAL, Mortgagor(s) herein. EXHIBIT A TO MORTGAGE.DOC . r.n.w IIIYI ■ 1 __.__..... _,. .._ .. x.. ..x.w.y. _�_... •. w- ._... .w.....yw.- ww...r. +.+wwr_r F7RDR ERT P. ZIEGLER E OF DEEDS ERLAND COUNTY THOUSE SQUARE CA.RLME, PA 17013 � • 717- 240 -6370 1 M Enstrutnent Number - 2o0937336 Recorded Oo 1.1/412009 At 11:00:45 AM * Tatal Pages - 11 { .Instrument Type - MORTGAGE Invoice No tuber - 554z3 User ID - XW * Mortgagor - HARRY, CRAIG E Mortgagee - MORTGAG,E EI.TCIROZtiIIC REGISTRATION SYSTRMS XNC Customer - MERCURY AnsTR&CT CO 6EES $ TATZ MXT UX $0.50 Certification page STATE JCS /ACCESS TO $10.04 XCORD DO NOT DETA RECORUTNG EMS — $23.50 RECORDER OF DEEDS PARCEtt CERTIMATrON $1 0,00 This page is now part FEES of this legal document. AMRD,ABLE HOUSING $11.50 COUNTY ARCHIVES rag $2.00 ROD ARCHMS Pzz $3100 TOT= PAID $50.50 1 I Certify this to be recorded in Cumberland County P A �a ) RECORRDER 0 D . " - I■tbrmation denoted by an eaterlsk may th■oge during the voAfi atian proaess and may not be refkckd ao this page, 1612013 &23!04 AM CUMBERLAND COUNTY InstO2009;17236 . fange 11 of 11 i 'F . V MIN Loan ID # Multistate NOTE FHA Case No. October 28th, 2009 YORK, PA [Dale] '[City] Islatel 5 FOREST AVENUE, MARYSVILLE, PENNSYLVANIA 17053 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means FIRST NATIONAL BANK OF CHESTER COUNTY THRU AM HOME BANK DIVISION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum Of One Hundred Seventeen Thousand Eight Hundred Twenty Six and no /100- - - - - - - Dollars (U.S. $ 117, 826.00 ) plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Five percent( 5.0 0 0 %) per year until die full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated tie same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on December 1st, 2009 . Any principal and interest remaining on the first day of November, 2039 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 3840 HEMPLAND ROAD, MOUNTVILLE, PA 17554 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $632.52 This amount will be part of a larger mondily payment required by the Security Instrument, that shall be applied to principal, interest and other items in die order described in fire Security Instrument. (D) Allonge to this Note for Payment Adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement die covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑ Graduated Payment Allonge ❑ Other [specify] ❑ Growing Equity Allonge 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, dhere will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by die Security Instrument, as described in Paragraph 4(C) of this Note by the end of Fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of die p b nce l ' Initials' FHA Midlistate Rate Note • 12/95 AAFNIG - 03051009 of 2 wMv.ProClosexom Loan ID ; remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at tare same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons drat amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of drat different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person if fully and personally obligated to keep all of the promises made in this Note, including fire promise to pay die full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agr o the t nd covenants contained in this Note. Paytd'the order of JPMorgan Chase Bank NA. (Seal) Without Recourse CRAIG E HARRY - Borrower First National Bank of Chester County Thru Am Morse Bank Division (Seal) - Borrower SUSAN R N D, AV (seal) -B gro wer al) the OrdQf e ' -Born wer paY ecAUn' � o a Chan SP terj (Se I) ePhns� is a Bar ower Sho (Seal) - Borrower [Sign Original Only] FSA Ministate Rate Note • 12/95 AAFMG • 03052009 Page 2 of 2 www.Proclose.cmn Chase (FL5 -7734) CHASE ! i P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 2171 3031 April 30, 2013 00022768 HDLO CB 12013 -BR840 CRAIG E HARRY 5 FOREST AVE MARYSVILLE, PA 17053 I W I tl Chase (FL5 -7734) CHASE ! i P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 2171 3031 April 30, 2013 11111111111111111111111111 00022768 HDLO CB 12013 -BR840 CRAIG E HARRY 5 FOREST AVE MARYSVILLE, PA 17053 Acceleration Warning (Notice of Intent to Foreclose) Account; (the "Loan ") Property Address: 5 FOREST AVE MARYSVILLE, PA 17053 (the "Property ") Dear CRAIG E HARRY: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument') securing your Loan, JPMorgan Chase Bank, N.A. ( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due March 1, 2013. 2. As of April 30, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $1,812.64 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848 -9380. Total Monthly Payments $1,742.92 Late Fees $69.72 NSF Fees $0.00 Other Fees* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized, for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of June 2, 2013 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before June 2, 2013, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure /attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848 -9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at (800) 569 -4287 or at www.hud.gov. Sincerely, Chase (800) 848 -9380 (800) 582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet 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 • 0 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 866 - 840 -5826. 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 - 9954673. 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. 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. BR840 An important message from the Federal Trade Commission U. n t o �a .Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell-tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so- called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD - certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. IUD Federal Trade Commission ftc.gov /MoneyMatters Call 1 -888- 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD - certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov 1 XAA HOPCNOW Support & Guidancefor Homeowners /■-I�%6LSM MAILING HOME AFFORDABLE.GOV Chase (FL5 -7734) CHASE P.O. Box 44090 NE Jacksonville, FL 32231 -4090 April 30, 2013 IIIIIIII1I111II1I11 Iloilo 11111 loll [III IIIIIII pill III 00022769 HDLO ZB 12013 -BR840 CRAIG E HARRY 5 FOREST AVE MARYSVILLE, PA 17053 Acceleration Warning (Notice of Intent to Foreclose) Account the "Loan ") Property Address: 5 FOREST AVE MARYSVILLE, PA 17053 (the "Property ") Dear CRAIG E HARRY: Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A. ( "Chase ") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due March 1, 2013. 2. As of April 30, 2013, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $1,812.64 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848 -9380. Total Monthly Payments $1,742.92 Late Fees $69.72 NSF Fees $0.00 Other Fees* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and /or permitted by applicable law, or that were authorized fbr services rendered. If'you need additional information regarding any of'these amounts, please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of June 2, 2013 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before June 2, 2013, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure /attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062 -8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 -9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848 -9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll -free at (800) 569 -4287 or at www.hud.gov. Sincerely, Chase (800) 848 -9380 (800) 582 -0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet 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 866 - 840 -5826. 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. 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. BR840 n � s An important message from the Federal Trade Commission A note to Homeowners Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, phone numbers, and "97% success rate!" websites to make it look like they're part of the "Guaranteed to save your home!" government. If you want to contact a government These kinds of claims are the tell-tale signs of a agency, type the web address directly into foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't an easy out. sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Don't Pay for a Promise Pages in your phone directory. Don't click on links Don't pay any business, organization, or person or open any attachments in unexpected emails. who promises to prevent foreclosure or get you a new mortgage. These so- called "foreclosure rescue Talk to a HUD - Certified companies" claim they can help save your home, Counseling Agency — For Free but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or request hefty fees in advance — and then stop you've already gotten a delinquency notice, free returning your calls. Others may string you along help is a phone call away. Call 1- 888 - 995 -HOPE before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling if someone insists on a fee. agencies certified by the U.S. Department of Housing and Urban Development (HUD). Send Payments Directly This national hotline — open 24/7 — is operated Some scammers offer to handle financial by the Homeownership Preservation Foundation, arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and your mortgage servicer. HUD- certified counseling agencies. For free guidance online, visit www.hopenow.com. For Don't Pay for a Second Opinion free information on the President's plan to help Have you applied for a loan modification and been homeowners, visit turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov. Federal Trade Commission I.��: ftc.gov /MoneyMatters � q Call 1- 888 - 995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD- certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov r n` iin H 0PEN0W Support . &.GuldanceTor Homeowners SM MAMNG HOME AFFORDABLE.GOV o k• Pennsylvania Verification Kathryn Coffee -House , hereby states that h s e s Vice President of JPMorgan Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn * o House authrities. t% JPMorgan Cha a Bank, N.A Borrower: L `� '9a I-W-3 Property dress. County: C.UMI)-f Last Four of Loan Number: FORM I : IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA, Plaintiff(s) c VS. t - tJ Craig E. Harry rte? 5 Forest Avenue _ Marysville, PA 17053 DEFENDANT Defendant(s) Civil - 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 with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: SHAPIRO & DeNARDO, LLC Date Attokpys for PI 'ntiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C O-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FIN ANCIAL • • First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes 11 No ❑ Y + y If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount Owed: Value: Automobile #2: Model: Year: Amount Owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paving) EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. Payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 1 � Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH ORIZATIO N I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole - purpose of evaluating m financial situation for possible mortgage options. I /We understand that I /We am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) f r+ FORM 3 IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Craig E. Harry 5 Forest Avenue Marysville, PA 17053 DEFENDANT Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: I. 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 unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith `� x� ' Chief Deputy Richard S W Stewart olicitor c� tSldAli JPMorgan Chase Bank, National Association vs. Case Number Craig E Harry 2013-5663 SHERIFF'S RETURN OF SERVICE 10/04/2013 06:58 PM- Deputy Jason Kinsler, 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 the Defendant, to wit: Occupant at 5 Forest Avenue, East Pennsboro, Marysville, PA 17053. JASON KI ER, DEPUTY 10/04/2013 06:58 PM-Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Lorie Hoffman, Girlfriend, who accepted as"Adult Person in Charge"for Craig E Harry at 5 Forest Avenue, East Pennsboro, Marysville, PA 17053. JASON INSI.�DEPUTY SHERIFF COST: $60.95 SO ANSWERS, October 07, 2013 RONNIV R ANDERSON, SHERIFF icj Cou.^:tvSwte Shenf.Te!eoWtt '..,,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION JP Morgan Chase,National Association • = C_.) Plaintiff No. 13-5663-Civil • cn Craig E. Harry • -Y Defendant % ° REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order datedcr �D , 70\3 , governing the Cumberland County 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 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 C.S. 4904 relating to unsworn falsification to authorities. Alr /7s 203 Defendant' 7 • I•• ed Legal Representative Date /•!,;% / /-2(57-a3)3 Defendant Date IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION • JP Morgan Chase,National Association Plaintiff No. 13-5663-Civil • v. • • Craig E. Harry • Defendant CERTIFICATE OF SERVICE AND NOW, this 2'3%'"" day of November, 2013, counsel for the Defendant hereby certifies that it has served the accompanying Request for Conciliation Conference upon the following persons and in the following manner which complies with the Pennsylvania Rules of Civil Procedure. Via first class mail: Cumberland County Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Via Certified Mail: Shapiro and DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Respectfully submitted, annah R Suhr, Es q.q The Morgan Law Firm 150 West Chocolate Ave. Hershey, PA 17033 (717)220-4300 hsuhr @fdeanmorgan.com PA ID No.: 311181 In Forma Pauperis Form JP Morgan Chase,National Association, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA • v. NO.2013- 5663 CIVIL TERM • Craig E. Harry, Defendant • IN CIVIL DIVISION PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Craig E. Harry,Defendant,to proceed in forma pauperis. I, Hannah R. Suhr, Esq. ,attorney for the party proceeding in forma pauperis,certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. /// Hannah R. Suhr,Esquire#3111 1 Attorney for Defendant The Morgan Law Firm 150 W.Chocolate Ave. Hershey,PA 17033 717-220-4300 hsuhr@fdeanmorgan.com r c.r ;;=. u) rti� J' ms'C' JP MORGAN CHASE,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUBERLAND COUNTY, PENNSYLVANIA a w �a vs. CIVIL ACTION M T-;. r7l r- -� CJ • r NO. 13-5663 CIVIL r— CRAIG E. HARRY, Defendant E CD CASE MANAGEMENT ORDER AND NOW, this 114 day of December, 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 ON , at 2. 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 defendantiborrower'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, Kevi . Hess, P.J. /Christopher DeNardo, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff S .Hannah R. Suhr, Esquire 3 150 West Chocolate Avenue Hershey, PA 17033 For the Defendant Am IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION JP Morgan Chase,National Association • =rn rri Plaintiff • No. 13-5663-Civil. ,r- 72,) V. • 5e:q • Craig E. Harry ;,.. Defendant CERTIFICATE OF SERVICE AND NOW,this 23(8 day of December, 2013,counsel for the Defendant hereby certifies that it has served the Form 2 - Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet upon the following persons and in the following manner which complies with the Pennsylvania Rules of Civil Procedure. Via Certified Mail: Shapiro and DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia,PA 19406 Respectfully submitted, /(:). Pt. Hannah R Suhr,Esq. The Morgan Law Firm 150 West Chocolate Ave. Hershey,PA ,17033 (717)220-4300 hsuhr @fdeanmorgan.com PA ID No.: 311181 • IC t. FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following,information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): L o E. Property Address: 5 For'P-t� y City: Ma-145t)+I(2.. State: Pit Zip: 1'7O S S Is the property for sale? Yes IF No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address-(if different): 0/ 4 City: State: Zip: Phone Numbers: Home: Office: Cell:1 r7-Qo3..! O(. Other: Email: VQ,rn.. Ho - oo. # of people in household 3 Long? y CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household How Long? FINANCIAL INFORMATION First Mortgage Lender: C.ka,p_R Type of Loan: C4 Pt Loan Number:fir_S I 01 S 34 9 4S-1(( Date You Closed Your Loan: MI zoo' Second Mortgage Lender: rU'l - Type of Loan: Loan Number: Total Mortgage Payments Amount:$ 91. c ) I cluded axes &Insurance: TAC( e..� Date of Last Payment: 31 2,0( Vim, c 2o13 Primary Reason for Default: ► ua LOSS Ca L-44-t-► -Q_ , - • _ , + Is the Loan +. Bankruptcy? Ye ❑ No CIL If yes,provide names, location of court, case number& attorney Assets Amount Owed Value Home: --., $ 1%143-4.'0 $ 1201 L4O6. 00 Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ 10, 0c) Savings: $ $ Other: $ $ Automobile#1: Model: 3 y akz. .. Year: Z.CU 2- Amount Owed: Value: Sot_ 1X3 Automobile#2: Model: akk..vk,( ' o.. e.C" Year: ZOO 2 Amount Owed: Value: l 000.00 Other transportation(automobiles, boats,motorcycles): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: I. J s Vi Rte. Grc.)ss 2. Neat-4,Cci,5 ( c — G ∎\\ GRUSs alv -- 1 • C 'Cc 7 3. Ac tic n 1I icome Description (not wages): 1.U.ntonp, . .. monthly amount: 341 o.cX� 2. monthly amount: Borrower Pay Days: i - � Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortage 7,7 1. 60 Food LAS.d° 2nd Mortgage Utilities 2tAS • 6 o _ Car Payment(s) -- Condo/Neigh. Fees Auto Insurance 1 C, •(.0 Med. (not covered) 40.00 Auto fuel/repairs S 33.00 Other prop. Payment Install. Loan Payment Cable TV 4.coil _ Child Support/Alim. Spending Money coo Day/Child Care/Tuit. — Other Expenses -Ms 2,0o, cD Amount Available for.Monthly Mortgage Payments Based on Income &Expenses: '4(go. 1 t' Have you been working with a Housing Counseling Agency? Yes 14 No 0 If yes,please provide the following information: Counseling Agency: 1v0.nli-� CC.S Counselor: t;\a Phone(Office): W6-S\•-D-D-22-1 Fax: '11-1- 5140-1U'4(, 2 Email: 6YY1 i ktzA..e..k` Q &at 11 '1 ACS . C Have you made application for Homeowners Emergency Mortgage Assistance Program ( EMAP) assistance? l Yes ❑ Not jam !" 19i b fi e_, If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes`I No D If yes,please indicate the status of those negotiations: it _' < < . � , +6 eASNIMtWre- Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name). � } o ,: Phone: 7400 ' y n 3co Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating in financial situation for possible mortgage options. I/We • understand that I/We am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: • Proof of income 4 Past 2 bank statements 4 Proof of any expected income for the last 45 days 4 Copy of a current utility bill • Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement.(if property is currently on the market) • jas 21-111, 0,1 in P ;= 1: 27 HANNAH R. SUHR, ESQ CUMBERLAN THE MORGAN LAW FIRM, LLC PENNS YL AN!T Y 813 E. Chocolate Avenue Hershey, PA 17033 717-220-4300 hsuhr@fdeanmorgan.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY • JP MORGAN CHASE, N.A., Plaintiff • CIVIL ACTION v. : No. 13-5663 CIVIL • CRAIG E. HARRY, • Defendant MOTION FOR CONTINUANCE AND NOW, this day of January, 2014, Petitioner, Craig E. Harry, by and through his counsel, Hannah R. Suhr, Esquire, files this Motion for Continuance and, in support thereof, avers as follows: 1. Movant is Attorney Hannah R. Suhr, Esquire and The Morgan Law Firm (hereinafter "Counsel") on behalf of Defendant Craig E. Harry, Defendant in the above matter. 2. Currently, the above matter is scheduled for Mortgage Conciliation Conference on January 24, 2014 at 4:00 p.m. 3. Defendant is unable to attend Court on this date and time as he has entered an inpatient rehabilitation facility for twenty-eight(28) days beginning on January 7, 2014. 4. Counsel respectfully requests that the matter be continued and rescheduled for after March 1, 2014. 5. Neither the Court nor the Commonwealth will be unduly prejudiced by rescheduling this matter for after March 1, 2014. 6. Counsel has contacted opposing counsel concerning this Motion for Continuance and has been told by Christopher DeNardo, Esq of Shapiro and DeNardo LLC, that the he does not oppose Counsel's request. WHEREFORE, Counsel respectfully requests that the above matter be rescheduled for after March 1, 2014. Respectfully submitted, Yannah R. Suhr, uire PA ID No: 311181 The Morgan Law Firm, LLC 813 E. Chocolate Ave. Hershey, PA 17033 Telephone: (717) 220-4300 hsuhr(cr�,fdeanmorgan.com Attorney for Defendant , ' PBJ P-336 COMMONWEALTH OF PENNSYLVANIA BOARD OF PROBATION AND PAROLE Parole No: 6115Q SPECIAL CONDITIONS OF PAROLE To: Craig Harry In addition to the conditions of parole previously imposed,you are subject to the following conditions,which are being imposed pursuant to Condition No. 7 of the original conditions governing your parole. On 01/07/2014, you must enroll in and successfully complete Inpatient Drug & Alcohol Treatment at Conewago Place. You must abide by all the rules and regulations of Conewago Place and its staff. You must also successfully complete all aftercare treatment as recommended by Conewago Place and/or Parole Supervision Staff. Any discharge or termination from Conewago Place, other than successful completion, will constitute a violation of your parole,which may result in your arrest. Should problems arise, or questions occur concerning the special conditions of your parole, consult with your Parole Agent,as it is his responsibility to help you in the interpretation of the Special Conditions of Parole. If you cannot reach your Parole Agent,you should contact the Agent in charge of the District Parole Office. If you believe the above Special Conditions are inappropriate,you may submit a timely complaint in writing, first to the supervisor of the district office under which you are being supervised. If your complaint is not resolved to your satisfaction, you may then submit your complaint in writing to the Director of Supervision. If your complaint is still not resolved to your satisfaction, you may then submit your complaint in writing to the Board Secretary for final disposition by the Board, The address for the Director of Supervisor and the Board Secretary is Pennsylvania Board of Probation and Parole,P. O.Box 1661,Harrisburg,Pennsylvania 17105-1661. If you violate any of the above special conditions, you will be subject to arrest and revocation of parole as if you had violated any of the original conditions. jACKNOWLEDGEMENT I here. , .j o edg: at I have read or have had read to me, the foregoing special conditions; I fully underst. ,d t- - -.-. , understa • the penalties involved should I in any manner vvio�late, e . --171 .1 i ti- i Ai•,/.41"/ 7...__70._-,Z • Parolee Signat f 7 `7 Date CV\P....A-e.----,t /1-1 / — 7 "' ?-7°P./ Parole Agent's Signature Date • • PBPP 348(10/99) PENNSYLVANIA BOARD OF PROBATION AND PAROLE PAROLE VIOLATION WARNT .G/INSTRUCTION Offender Name. /4c(--(/ Parole No. L Date of Warnini/Inztructio • / - 7 )_ 1, y Time: / Warning/Violation(s): Instructions to Offender: 104. Ct -• b-„) -5-4. 0 (r) i!S CV-4) C_St G, , • ffC,r4.--G6-e • • • 1 Supervision Staft___, Signature Ii 4A, ANEM07 Offender's Eat- Are0-4, Sign.ature • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY • JP MORGAN CHASE,N.A., Plaintiff • CIVIL ACTION • • v. • No. 13-5663 CIVIL • • • CRAIG E. HARRY, • Defendant CERTIFICATE OF SERVICE AND NOW, this of January, 2014, counsel for the Defendant hereby certifies that it has served the accompanying Motion for Continuance upon the following persons and in the following manner which complies with the Pennsylvania Rules of Criminal Procedure. Via email: Christopher DeNardo, Esq. Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Respectfully submitted, c: * Hannah R. Suhr, E . The Morgan Law Firm, LLC 813 E. Chocolate Ave. Hershey, PA 17033 (717) 220-4300 dean@fdeanmorgan.com PA ID No.: 311181 Attorney for the Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY • JP MORGAN CHASE, N.A., Plaintiff : CIVIL ACTION • N n v. No 13-5663 CIVIL _'` • zrn CRAIG E. HARRY, cz Defendant • N am ORDER r.� AND NOW, this g/.4,-t day of January, 2014, upon consideration of the herein Motion for Continuance, it is hereby Ordered and Decreed that the Mortgage Conciliation Conference in the above-referenced matter is hereby continued until j��Q j, , 7 , 2014 at 3:a) /0 .m. in_ej of the Cumberland County Courthouse. BY THE COURT: -79 cit.-. 9istribution: ✓ H nnah R. Suhr, Esq., The Morgan Law Firm, LLC 813 E. Chocolate Ave., Hershey, PA 17033 ristopher DeNardo, Esq., Shapiro and DeNardo, LLC, 3600 Horizon Drive, Suite 150, King of 4crussia,PA 19406 i/Q.e1.11 e . Cc? 'es /YLailizt zi JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-5663 CIVIL CRAIG E. HARRY, Defendant IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held March 7, 2014, were David Baric, Esquire, local counsel for the plaintiff; Hannah R. Suhr, Esquire, attorney for the defendant; and the homeowner, Craig E. Harry. Despite some confusion, it appears that the documents necessary for the bank's review have been submitted or will be submitted within ten (10) days. In order to give the plaintiff sufficient time to review this matter, continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this day of March, 2014, continued conciliation conference is set for Friday, April 25, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, A;ristopher DeNardo, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff ,6avid Buie, Esquire 19 West South Street Carlisle, PA 17013 Local Counsel for Plaintiff „„Vrlannah R. Suhr, Esquire 150 West Chocolate Avenue Hershey, PA 17033 For the Defendant s frat Is-cL 3//0/tcf JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. CRAIG E. HARRY, Defendant : CIVIL ACTION : NO. 13 -5663 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 g 4 day of April, 2014, it appearing that the last of the required documents necessary for review have been submitted to the bank and continued conciliation conference is set for Friday, June 6, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, /Caitlin M. Donnelly, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For he Plaintiff Hannah R. Suhr, Esquire 150 West Chocolate Avenue Hershey, PA 17033 For the Defendant :rim Cc ES t 6cL, 40.8M JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. CRAIG E. HARRY, Defendant : CIVIL ACTION : NO. 13-5663 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 6.- day of June, 2014, on condition that the defendant submit the documents requested during today's conciliation conference within ten (10) days, continued conciliation conference is set for Friday, July 18, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, Bradley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff G�7 Hannah R. Suhr, Esquire 150 West Chocolate Avenue Hershey, PA 17033 r For the Defendant >(-) D :rlm C.Op ;CS' itri-tita /l JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-5663 CIVIL CRAIG E. HARRY, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / * day of July, 2014, in order to give the defendant time to secure new counsel, the conciliation conference set for July 18, 2014, is continued to Friday, August 22, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Xadley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff ✓ Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 Local Counsel for Plaintiff Craig Harry 5 Forest Avenue Marysville, PA 17053 :rim 'e,s' Pal isiL. /7//y Kevin : Hess, P.J. C -)Fri C33 Fri i 4-4 P MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs. CRAIG E. HARRY, : NO.: 13-5663 CIVIL Defendant ENTRY OF APPEARANCE c--) z -c) Please enter my appearance on behalf of the Defendant in the above matter for purposes of providing counsel for participation in the Cumberland County Residential Mortgage Foreclosure Diversion Program only and not for the foreclosure action in general. Respectfully submitted, SAIDIS SULLIVAN & ROGERS Dated: August /3 , 2014 By: TEF4EN L. GROSE c47-4— Attorney I.D. #31006 CERTIFICATE OF SERVICE I, Stephen L. Grose, Esquire, one of the attorneys for Defendant ereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Bradley Osborne, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 SAIDIS SULLIVAN & ROGERS By: Dated: August 13 , 2014 Step en L. Grose JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-5663 CIVIL CRAIG E. HARRY, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 e day of August, 2014, after conciliation conference, it appearing that a new packet has been submitted to the lender and is complete with the exception of one or two documents, in order to give the lender the opportunity to conduct its review, continued conciliation conference is set for Friday, October 17, 2014, at 2:30 p.m. in Chambers of the undersigned. .. Bradley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 BY THE COURT, Kevin Hess, P.J. For the Plaintiff c-) -7 a c 3 Stephen L. Grose, Esquire rrl m = r•n 635 N. 12th Street, 4th Floor CD rte'- Lemoyne, PA 17043 r r- ' -i �. For the Defendant < -r,� :rim x' r>)`, -r r.- 8 'ES fiNt (£411/4. egt7.11./g/ .-;�3 JP MORGAN CHASE, N.A., Plaintiff vs. CRAIG E. HARRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUBERLAND COUNTY, PENNSYLVANIA • : CIVIL ACTION : NO. 13-5663 CIVIL 1N RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 $' day of August, 2014, at the request of counsel for the defendant, the conciliation conference set for October 17, 2014, is continued to Friday, October 24, 2014, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, .Bradley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff than Wolf, Esquire 10 W. High Street Carlisle, PA 17013 /Stephen L. Grose, Esquire 635 N. 12th Street, 4th Floor Lemoyne, PA 17043 For the Defendant :rim l p Es P221 8A9py LC' c,--11,a4141‘cAly aoiyPin ?/ 'l/ A.Q4.1.sy �� z `Ts�j JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-5663 CIVIL CRAIG E. HARRY, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 7-1-'4 day of October, 2014, at the request of counsel, the conciliation conference set for October 24, 2014, is continued to Friday, December 5, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin Hess, P.J. radley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff than Wolf, Esquire 10 W. High Street Carlisle, PA 17013 ‘hen L. Grose, Esquire 635 N. 12th Street, 4th Floor Lemoyne, PA 17043 For the Defendant 44. JP MORGAN CHASE, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA vs. CRAIG E. HARRY, Defendant : CIVIL ACTION : NO. 13-5663 CIVIL ORDER AND NOW, this Z '4 day of December, 2014, at the request of counsel, the conciliation conference set for December 5, 2014, is cancelled. Further, on agreement of the parties, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay previously entered in this case is lifted. BY THE COURT, Bradley Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff Nathan Wolf, Esquire 10 W. High Street Carlisle, PA 17013 ✓Stephen L. Grose, Esquire 635 N. 12th Street, 4th Floor Lemoyne, PA 17043 For the Defendant