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HomeMy WebLinkAbout13-6566 Supreme Cou.rt,of Pennsylvania Cour , Commo.` '.,Pleas ` For Prothonotary Use Only: vCove eet ..,r v t. i CUMBERA County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: D Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: JPMORGAN CHASE BANK, Lead Defendant's Name: WESLEY F. GRIFFIS A/K/A WESLEY T NATIONAL ASSOCIATION GRIFFIS I Are money damages requested? El Yes 0 No Dollar Amount Requested: E3 within arbitration limits Q (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes 0 No A Name of Plaintiff/Appellant's Attorney: Adam H. Davis Eso.. Id. No.203034 Phelan Hallinan LLP ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one.type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: Q ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common LawiStatutory 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: Pa.R.C.P. 205.5 Updated 01/01/2011 !LEfJ - 01 7 F IICr CUI,IOERLAND COUNTY PENNSYLVANIA PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215 -563 -7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION COURT OF COMMON PLEAS 1111 POLARIS PARKWAY COLUMBUS, OH 43240 CIVIL DIVISION Plaintiff TERM NO. WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS 105 SPRINGHOUSE ROAD CUMBERLAND COUNTY SHIPPENSBURG, PA 17257 -1120 DEBRA D. DANGLO - GRIFFIS A/K/A DEBRA DANGLO- GRIFFIS 105 SPRINGHOUSE ROAD SHIPPENSBURG, PA 17257 -1120 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE AA 'Slog a � File #: 926710 C 31vs�29s 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 1111 POLARIS PARKWAY COLUMBUS, OH 43240 2. The name(s) and last known address(es) of the Defendant(s) are: WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS 105 SPRINGHOUSE ROAD SHIPPENSBURG, PA 17257 -1120 DEBRA D. DANGLO - GRIFFIS A/K/A DEBRA DANGLO - GRIFFIS 105 SPRINGHOUSE ROAD SHIPPENSBURG, PA 17257 -1120 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/15/2010 WESLEY F. GRIFFIS and DEBRA D. DANGLO - GRIFFIS made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 201037309. By Assignment of Mortgage recorded 07/03/2013 the mortgage was assigned to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, which Assignment is recorded in Assignment of Mortgage Instrument No. 201322119.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves JPMORGAN CHASE BANK, NATIONAL ASSOCIATION from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 926710 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 07/18/2013: Principal Balance $98,184.57 Interest from $1,472.76 03/01/2013 through 06/30/2013 Late Charges $103.45 Property Inspections $43.00 Subtotal $99,803.78 Less Escrow Balance 800.22 TOTAL $99,003.56 7. Plaintiff is not seeking a judgment of personal liability (or an in person am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 926710 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $99,003.56, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff File #: 926710 LEGAL DESCRIPTION ALL that certain piece or parcel of land, with the dwelling house thereon erected, situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, designated on the Oakland Park Plot of building lots in Block "O ", Lot NO. 10, said plot to be left for recording in the Office of the Recorder of Deeds in and for said Cumberland County, bounded and described as follows: BEGINNING at a point on the North side of Spring House Road at line of Lot NO. 9 now or formerly of Harold Clough; thence with said Clough land, Northwardly 125 feet to line of Lot No. 16 of the West End Land Company of Shippensburg; thence with said Lot NO. 16, Eastwardly 50 feet to a line of Lot No. 12 of the West End Land Company of Shippensburg, thence with said Lot No. 12 and Lot No. 11 of the West End Land Company of Shippensburg, Southwardly 125 feet to the North side of Spring House Road; thence with said North side of Spring House Road, Westwardly 50 feet to the first mentioned point and place of BEGINNING. Extending in even width 125 feet to Lot No. 16 of the West End Land Company of Shippensburg in the rear. PROPERTY ADDRESS: 105 SPRINGHOUSE ROAD, SHIPPENSBURG, PA 17257 -1120 PARCEL #34 -34 -2417 -052. File #: 926710 VERIFICATION hereby states that he she 's Vice President of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Vice Pr +ent h Date: t� a�_�l JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Borrower: GRIFFIS Property Address: 105 SPRINGHOUSE ROAD, SHIPPENSBURG, PA 17257 -1120 County: CUMBERLAND Last Four of Loan Number: 8822 File #: 926710 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 926710 FORM 1 IN THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK, NATIONAL OF CUMBERLAND COUNTY, PENNSYLVANIA ASSOCIATION G Plaintiff(s) vs. Ln Y' WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS p DEBRA D. DANGLO- GRIFFIS A/K/A DEBRA ,—_ a � DANGLO-GRIFFIS Defendant(s) Civil .vt. 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) 2439400 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 praide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, 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 willhave 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 hat a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zlp Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorc�cles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1: monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 nd 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 Mone Da /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: 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 known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: 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 my financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) i 6. Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -.1 LJ°+J>F I: _ Sheriff 0 Cturibt r THE PROTHONO Ai:. {. Jody S Smith �`ttr ?;r,, 4 Chief Deputy . - ry 2(113 DEC -6 PM 12: 02 Richard W Stewart " CUMBERLAND Solicitor oFF"C- r rte-ft.$ C RFF MBERLAND COUN I =f PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. Wesley F Griffis (et al.) 2013-6566 • SHERIFF'S RETURN OF SERVICE • 11/08/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra D Danglo-Griffis, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. • 11/12/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra D Danglo-Griffis, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 105 Springhouse Road, Shippensburg Borough, Shippensburg, PA 17257. Residence is vacant and per the Shippensburg Postmaster the defendant moved and left no forwarding address. 11/12/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Wesley F Griffis, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 105 Springhouse Road, Shippensburg Borough, Shippensburg, PA 17257. Residence is vacant and per the Shippensburg Postmaster the defendant moved and left no forwarding address. 11/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Wesley F Griffis, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 29 S. Pitt Street Apt. 1, Carlisle Borough, Carlisle, PA 17013. Deputies were advised the current resident Lisa Hearn moved in on November 8, 2013 and that the defendants no longer reside at this address. 11/13/2013 09:59 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra D Danglo-Griffis, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 29 S. Pitt Street Apt. 1, Carlisle Borough, Carlisle, PA 17013. Deputies were advised the current resident Lisa Hearn moved in on November 8, 2013 and that the defendants no longer reside at this address. 11/22/2013 09:47 AM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon John Danglo, Son, , who accepted for Debra D Danglo-Griffis, at 109 Marco Circle, Shippensburg, PA 17257. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $118.38 SO ANSWERS, December 03, 2013 RONNY R ANDERSON, SHERIFF • {c)CourV&A:0 Sheriff,Tc,eoscit.L'c. SHERIFF' S RETURN - REGULAR CASE NO: 2013-00344 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN JPMORGAN CHASE BANK NA VS DEBRA D DANGLO-GRIFFIS ET AL ANGEL L LAVIENA , Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon DANGLO-GRIFFIS DEBRA D the DEFENDANT , at 0947 : 00 Hour, on the 22nd day of November , 2013 at 109 MARCO CIRCLE SHIPPENSBURG, PA 17257 by handing to JOHN DANGLO SON a true and attested copy of COMP MORT FORE together with and at the same time directing His attention to the contents thereof . Sheriff ' s Costs : So Answers : Docketing . 00 Service . 00 ANGEL Affidavit . 00 Ilk,Surcharge . 00 By. 00 `epuy Sheriff . 00 11/26/2013 PHELAN HALLINAN Sworn and Subscribed to before me this day of COMMONWEALTH OF PENNSYLVANIA NC A IAI SEAL RICHARD C. McCARTY, Notary Public .. . A.D. Chsmh r$burq Boro., Franklin County j hRy iainn o`xpfres Jan. 29,2015 I Notary // 45;" otary 4 DEC t 6 AM tO� 28 PHELAN HALLINAN,LLP Meredith Wooters,Esq.,Id.No.307207 • 2G13 CUMBERLAND COUNT? 1617 JFK Boulevard, Suite 1400 PEHtSYLVAHI✓` One Penn Center Plaza . Philadelphia,PA 19103 Meredith.Wooters @phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL : COURT OF COMMON PLEAS ASSOCIATION Plaintiff : CIVIL DIVISION vs. : CUMBERLAND COUNTY • WESLEY F. GRIFFIS A/K/A WESLEY : No. 13-6566-CIVIL GRIFFIS DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA : DANGLO-GRIFFIS Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN,LLP / By: !kit /Air / Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Date: i a l3 i 3 /nru, Svc Dept. File#926710 S`1,15 CL4 13-7 S 3 d 0101 Li, (442 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson "-0 Sheriff Jody S Smith VIN1111 - Chief Deputy s ' Richard W Stewart c Solicitor �� � JPMorgan Chase Bank, N.A. Case Number vs. Wesley F Griffis(et al.) 2013-6566 SHERIFF'S RETURN OF SERVICE 01/13/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Wesley F Griffis, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 18 Hollar Avenue,Apt. 3, Shippensburg Borough, Shippensburg, PA 17257. Per the Shippensburg Postmaster the defendant moved and left no forwarding address. SHERIFF COST: $55.60 SO ANSWERS, January 13, 2014 RON _ R ANDERSON, SHERIFF l TH PR0TH0j#go TAR'J 2014 JAN 24 AM 42 PHELAN HALLINAN,LLP Emily M.Phelan,Esq.,Id.No.315250 CUM LAND GOUt4TY 1617 JFK Boulevard,Suite 1400 P"f9YLVANIA One Penn Center Plaza Philadelphia,PA 19103 emily.phelan@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS ASSOCIATION Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY WESLEY F. GRIFFIS A/K/A WESLEY No. 13-6566-CIVIL GRIFFIS DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO-GRIFFIS Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PH EL HALLINAN,LLP _ By: Emily M. Phelan, Esq., Id. No 315250 Attorney for Plaintiff Date: /nru, Svc Dept. File#926710 Soo,93 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ).1, i:r i Ip': Sheriff C, _ fib { H;C,,'t ; i ±t C3?'Y,.cr .J'i 4a71P i:•1 ti tJ`� Jody S Smith r R FEa 1 I Pi's 3: 1 7 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. Wesley F Griffis(et al.) 2013-6566 SHERIFF'S RETURN OF SERVICE 02/04/2014 11:46 AM - Deputy William Cline, 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 Teresa Heinbaugh, Girlf•-lid, o accepted as "Adult Person in Charge"for Wesley F Griffis at 338 B Street, Carlisle Boro • , C-� : PA 17013. A 4411.11W'. Afr"AM CLINE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, February 05, 2014 RONIJY R ANDERSON, SHERIFF PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P, 3180-3183 JPMorgan Chase Bank, National Association Plaintiff V. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 05/28/2014 to Date of Sale ($16.27 per diem) TOTAL Note: Please attach description of property. PH # 926710 da ES U. is° It lt 44 (A Ll U.o. SOIL it &72 Yo C X/ N yeR Pii--&)0(40, COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -6566 -CIVIL CUMBERLAND COUNTY $99,003.56 $1,610.73 $100,614.29 Phe n Hallinan, LLP Jonathan Lobb, Esq., Id. No.312 Attorney for Plaintiff C) LEGAL DESCRIPTION ALL that certain piece or parcel of land, with the dwelling house thereon erected, situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, designated on the Oakland Park Plot of building lots in Block "O", Lot NO. 10, said plot to be left for recording in the Office of the Recorder of Deeds in and for said Cumberland County, bounded and described as follows: BEGINNING at a point on the North side of Spring House Road at line of Lot NO. 9 now or formerly of Harold Clough; thence with said Clough land, Northwardly 125 feet to line of Lot No. 16 of the West End Land Company of Shippensburg; thence with said Lot NO. 16, Eastwardly 50 feet to a line of Lot No. 12 of the West End Land Company of Shippensburg, thence with said Lot No. 12 and Lot No. 11 of the West End Land Company of Shippensburg, Southwardly 125 feet to the North side of Spring House Road; thence with said North side of Spring House Road, Westwardly 50 feet to the first mentioned point and place of BEGINNING. Extending in even width 125 feet to Lot No. 16 of the West End Land Company of Shippensburg in the rear. TITLE TO SAID PREMISES IS VESTED IN Wesley F. Griffis and Debra D. Danglo-Griffis, h/w, by Deed from J. Michael Alder and Marlene B. Alder, h/w, dated 12/15/2010, recorded 12/16/2010 in Instrument Number 201037308. PREMISES BEING: 105 Springhouse Road, Shippensburg, PA 17257-1120 PARCEL NO. 34-34-2417-052. PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 HRO MON' 4.Y27 fil 9:5 CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, National Association Plaintiff v. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13 -6566 -CIVIL . Cumberland County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Ph n Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff V JPMorgan Chase Bank, National Association Plaintiff v. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -6566 -CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, National Association, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 105 Springhouse Road, Shippensburg, PA 17257-1120. 1. Name and address of Owner(s) or reputed Owner(s): Name Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis 2. Name and address of Defendant(s) in the judgment: Name Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Address (if address cannot be reasonably ascertained, please so indicate) 338 B St Carlisle, PA 17013-1824 109 Marco Circle Shippensburg, PA 17257-8934 Address (if address cannot be reasonably ascertained, please so indicate) 338 B St Carlisle, PA 17013-1824 109 Marco Circle Shippensburg, PA 17257-8934 r -r7 `7.7 O 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real progerty tobe s61121;- Name 6ldName Address (if address cannot be _r Northeastern Supply, Inc. Northeastern Supply, Inc. C/O James W. Adelman, Esquire reasonably ascertained, please indicate) 8323 Pulaski Highway Baltimore, MD 21237 201 North Presidential Boulevard Suite 100 Bala Cynwyd, PA 19004 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. PH # 926710 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Debra Danglo-Griffis C/O Mark F. Bayley, Esquire Wesley Griffis C/O Hannah Herman -Snyder, Esquire Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building 105 Springhouse Road Shippensburg, PA 17257-1120 17 West South Street Carlisle, PA 17013 200 North Hanover Street Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: 4 /23)1q PH # 926710 By: PhelHallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 • i. • . • • I `• ,L,, JPMorgan Chase Bank, National Asoeta,pitr p - : COURT OF COMMON PLEAS c: 1 A11 9:53 CUMBERLANn Plaintiff : CIVIL DIVISION PEN,kis yal/ALIV,Jeia'11-;" vs. : NO.: 13 -6566 -CIVIL Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis : Cumberland County Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wesley F. Griffis a/k/a Wesley Griffis 338 B St Carlisle, PA 17013-1824 Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis 109 Marco Circle Shippensburg, PA 17257-8934 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WELL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 105 Springhouse Road, Shippensburg, PA 17257-1120 is scheduled to be sold at the Sheriff's Sale on 09/03/2014 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $99,003.56 obtained by JPMorgan Chase Bank, National Association (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13 -6566 -CIVIL JPMorgan Chase Bank, National Association v. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis owner(s) of property situate in SHIPPENSBURG BOROUGH, CUMBERLAND County, Pennsylvania, being 105 Springhouse Road, Shippensburg, PA 17257-1120 Parcel No. 34-34-2417-052. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $99,003.56 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL that certain piece or parcel of land, with the dwelling house thereon erected, situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, designated on the Oakland Park Plot of building lots in Block "0", Lot NO. 10, said plot to be left for recording in the Office of the Recorder of Deeds in and for said Cumberland County, bounded and described as follows: BEGINNING at a point on the North side of Spring House Road at line of Lot NO. 9 now or formerly of Harold Clough; thence with said Clough land, Northwardly 125 feet to line of Lot No. 16 of the West End Land Company of Shippensburg; thence with said Lot NO. 16, Eastwardly 50 feet to a line of Lot No. 12 of the West End Land Company of Shippensburg, thence with said Lot No. 12 and Lot No. 11 of the West End Land. Company of Shippensburg, Southwardly 125 feet to the North side of Spring House Road; thence with said North side of Spring House Road, Westwardly 50 feet to the first mentioned point and place of BEGINNING. Extending in even width 125 feet to Lot No. 16 of the West End Land Company of Shippensburg in the rear. TITLE TO SAID PREMISES IS VESTED IN Wesley F. Griffis and Debra D. Danglo-Griffis, h/w, by Deed from J. Michael Alder and Marlene B. Alder, h/w, dated 12/15/2010, recorded 12/16/2010 in Instrument Number 201037308. PREMISES BEING: 105 Springhouse Road, Shippensburg, PA 17257-1120 PARCEL NO. 34-34-2417-052. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. NO 13-6566 Civil Term CIVIL ACTION — LAW WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO-GRIFFIS WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $99,003.56 L.L.: $.50 Interest FROM 5/28/2014 TO DATE OF SALE ($16.27 PER DIEM) - $1,61.0.73 Atty's Comm: Due Prothy: $2.25 Atty Paid: $381.01 Other Costs: P iff Pa Date: 5/27/14 Th IS-Lt (Seal) REQUESTING PARTY: Name: JONATHAN LOBB, ESQUIRE Address: 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 312174 David D. Buell, Prothonotary qaY: .62J1.„_,P,creoweLir— Deputy d` 4 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r rt;E S:lfE:RIFF OF THE PROTHONOTARY TARY 2@11, AUG 29 PH 2: >? I CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. vs. Case Number Wesley F Griffis (et al.) 2013-6566 SHERIFF'S RETURN OF SERVICE 06/16/2014 08:45 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Wesley F Griffis at 338 B Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 06/23/2014 12:01 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 105 Springhouse Road, Shippensburg - Borough, Shippensburg, PA 17257, Cumberland County. 08/06/2014 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/3/2014 08/07/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $772.47 SO ANSWERS, August 28, 2014 RONNY R ANDERSON, SHERIFF ;z' a -1197g/ A/-0- 3.01/,A (c) CourrtySu to 5,'neriff, Teleosoft, Inc. zo .• • (.1 .".1 `•- On May 23, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Borough, Known and numbered as, 105 Springhouse Road, Shippensburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 23, 2014 By: Real Estate Coordinato LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-6566 Civil JPMORGAN CHASE BANK, N.A. vs. WESLEY F. GRIFFIS Debra D. Danglo-Griffis Atty.: Joseph Schalk By virtue of a Writ of Execution No. 13 -6566 -CIVIL. JPMorgan Chase Bank, National Association v. Wesley F. Griffis a/k/a Wesley Griffis, Debra D. Danglo-Griffis a/k/a Debra Danglo- Griffis owner(s) of property situate in SHIPPENSBURG BOROUGH, CUM- BERLAND County, Pennsylvania, being 105 Springhouse Road, Ship- pensburg, PA 17257-1120. Parcel No. 34-34-2417-052. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $99,003.56. 49 i PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 5 day of July, 2014 r Notary COMMONWEALTH OF PENNSYLVANIA 1 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. '41900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriot Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this'statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013-6566 CMI Term JPMORGAN CHASE BANK, N.A. vs. WESLEY F GRIFFIS Debra D Danglo-Griffis Atiy: Joseph Schalk By virtue of a Writ of Execution No. 13 -6566 -CIVIL JPMorgan Chase Bank, National Association v. Wesley E. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis owner(s) of property situate in SH1PPENSBURG BOROUGH, CUMBERLAND County, Pennsylvania, being 105 Springhouse Road, Shippensburg, PA 17257-1120 Parcel No. 34-34-241.7-052. (Acreage or street address) thereon: Improvements RESIDENTIAL DWELLING Judgment Amount: $99,003.56 This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 Sworn to and bscribed before me this 20 day of August, 2014 A.D. COMMON ALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 JPMorgan Chase Bank, National Association Plaintiff V. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 05/28/2014 to Date of Sale ($16.27 per diem) TOTAL Note: Please attach description of property. PH # 926710 : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13 -6566 -CIVIL : CUMBERLAND COUNTY $99,003.56 $4,571.87 $103,575.43 C4.7' P n Hallinan, LLP ' o h E. DeBarberie, Esq., Id. No.31542i Attorney for Plaintiff . -sr. LEGAL DESCRIPTION ALL that certain piece or parcel of land, with the dwelling house thereon erected, situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, designated on the Oakland Park Plot of building lots in Block "0", Lot NO. 10, said plot to be left for recording in the Office of the Recorder of Deeds in and for said Cumberland County, bounded and described as follows: BEGINNING at a point on the North side of Spring House Road at line of Lot NO. 9 now or formerly of Harold Clough; thence with said Clough land, Northwardly 125 feet to line of Lot No. 16 of the West End Land Company of Shippensburg; thence with said Lot NO. 16; Eastwardly 50 feet to a line of Lot No. 12 of the West End Land Company of Shippensburg, thence with said Lot No. 12 and Lot No. 11 of the West End Land Company of Shippensburg, Southward]y 125 feet to the North side of Spring House Road; thence with said North side of -Spring House Road, Westwardly 50 feet to the first mentioned point and place of BEGINNING. Extending in even width 125 feet to Lot No. 16 of the West End Land Company of Shippensburg in the rear. TITLE TO SAID PREMISES VESTED IN Wesley F. Griffis and Debra D. Danglo-Griffis, h/w, by Deed from J. Michael Alder and Marlene B. Alder, h/w, dated 12/15/2010, recorded 12/16/2010 in Instrument Number 201037308. PREMISES BEING: 105 Springhouse Road, Shippensburg, PA 17257-1120 PARCEL NO. 34-34-2417-052. PHELAN HALLINAN, LLP Joseph E. DeBarberie, Esq., Id. No.315421 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 joseph.debarberie@phelanha n n.corn 215-563-7000 JPMorgan Chase Bank, National Association Plaintiff V. .±.PLED -OFFICE PIW THONO TA 11 25 Attorneys for Plaintiff &I NOV 6 ,Q Ctil'iBERLA0 COUNTY PENNSYLVANIA Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) CERTIFICATION : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13 -6566 -CIVIL CUMBERLAND County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: P e an Hallinan, LLP ph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff JPMorgan Chase Bank, National Association Plaintiff v. 'Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -6566 -CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, National Association, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 105 Springhouse Road, Shippensburg, PA 17257-1120. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Wesley F. Griffis a/k/a Wesley Griffis 338 B St Carlisle, PA 17013-1824 Debra D. Danglo-Griffis a/k/a Debra Danglo- 109 Marco Circle Griffis 2. Name and address of Defendant(s) in the judgment: Name Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo- Griffis Shippensburg, PA 17257-8934 Address (if address cannot be reasonably ascertained, please so indicate) 338 B St Carlisle, PA 17013-1824 109 Marco Circle Shippensburg, PA 17257-8934 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Northeastern Supply, Inc. 8323 Pulaski Highway Baltimore, MD 21237 Northeastern Supply, Inc. CIO James W. Adelman, Esquire 201 North Presidential Boulevard Suite 100 Bala Cynwyd, PA 19004 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) PH # 926710 None. 6. Name and address of every other person who has any record intereSi in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Debra Danglo-Griffis CIO Mark F. Bayley, Esquire Wesley Griffis C/0 Hannah Herman -Snyder, Esquire Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building 105 Springhouse Road Shippensburg, PA 17257-1120 17 West South Street Carlisle, PA 17013 200 North Hanover Street Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. # 926710 4110 • i1an Hallinan, LLP •eph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 O TtFcIr �oTtj #O TAW( I r JPMorgan Chase Bank, National Associationd p 18 4;1 ' q iI• vs. 26: CUM3Ei LAt u COUNTY: PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -6566 -CIVIL Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis : CUMBERLAND County Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Wesley F. Griffis a/k/a Wesley Griffis 338 B st Carlisle, PA 17013-1824 Debra D. Danglo-Griffis a/k/a Debra Danglo- Griffis 109 Marco Circle Shippensburg, PA 17257-8934 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 105 Springhouse Road, Shippensburg, PA 17257-1120 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $99,003.56 obtained by JPMorgan Chase Bank, National Association (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the yalue of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13 -6566 -CIVIL JPMorgan Chase Bank, National Association v. Wesley F. Griffis a/k/a Wesley Griffis Debra D. Danglo-Griffis a/k/a Debra Danglo-Griffis owner(s) of property situate in the SHIPPENSBURG BOROUGH, CUMBERLAND County, Pennsylvania, being 105 Springhouse Road, Shippensburg, PA 17257-1120 Parcel No. 34-34-2417-052. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $99,003.56 Attorneys for Plaintiff Phelan Hallinan. LLP LEGAL DESCRIPTION ALL that certain piece or parcel of land, with the dwelling house thereon erected, situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, designated on the Oakland Park Plot of building lots in Block "O", Lot NO. 10, said plot to be left for recording in the Office of the Recorder of Deeds in and for said Cumberland County, bounded and described as follows: BEGINNING at a point on the North side of Spring House Road at line of Lot NO. 9 now or formerly of Harold Clough; thence with said Clough land, Northwardly 125 feet to line of Lot No. 16 of the West End Land Company of Shippensburg; thence with said Lot NO. 16, Eastwardly 50 feet to a line of Lot No. 12 of the West End Land Company of Shippensburg, thence with said Lot No. 12 and Lot No. 11 of the West End Land Company of Shippensburg, Southwardly 125 feet to the North side of Spring House Road; thence with said North side of Spring House Road, Westwardly 50 feet to the first mentioned point and place of BEGINNING. Extending in even width 125 feet to Lot No. 16 of the West End Land Company of Shippensburg in the rear. TITLE TO SAID PREMISES VESTED IN Wesley F. Griffis and Debra D. Danglo-Griffis, h/w, by Deed from J. Michael Alder and Marlene B. Alder, h/w, dated 12/15/2010, recorded 12/16/2010 in Instrument Number 201037308. PREMISES BEING: 105 Springhouse Road, Shippensburg, PA 17257-1120 - -PARCEL NO. 34-34-2417-052. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 wwvv.ecpa,net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs, NO 13-6566 Civil Term CIVIL ACTION — LAW WESLEY F. GRIFFIS AlIC A WESLEY GRIFFIS DEBRA D. DANGLO-GRIFFIS A/KJA DEBRA DANGLO-GRIFFIS WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $99,003.56 L.L.: Interest FROM 05/28/2014 TO DATE OF SALE ($16.27 PER DIEM) - $4,571.87 Atty's Comm: Atty Paid: $1,181.98 Plaintiff Paid: Date: 11/18/14 (Seal) REQUESTING PARTY: Name: JOSEPH E. DEBARBERIE, ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BLVD., SUITE 1400 Attorney for: PLAINTIFF Telephone: 215- SZ3 - %WC` Supreme Court ID No 3/svai Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary PLAINTIFF AFFIDAVIT OF SERVICE CUMBERLAND COUNTY JPMORGAN CHASE BANK, NATIONAL ASSOCIATION DEFENDANT WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO-GRIFFIS SERVE DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO- GRIFFIS AT: 109 MARCO CIRCLE SHIPPENSBURG, PA 17257-8934 **DIVORCED- One cannot accept service for the other** SERVED PH # 926710 SERVICE TEAM/ lxh COURT NO.: 13 -6566 -CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 41 Served iiiitd made known to DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO-GRIFFIS, Defendant„or ilie ;1 day of NOR wt 6$20 at 02 ; 3tqo'clock f M., at / 0 iti 9 fa) (j £1 P , in he manner de cribed below. Defendant personally serve 1 ct'tr%51 V Yo, > 'pi Adult family member with whom De dant(s) resides). R Relationship is Ii �} aN �� v'= S Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: ` . i� CODescr ption: Age i+� He' h�� Weight � Race W � Sex /-( Other /00 , \D-056' r V� t. -- I, E'we�. 1•�A ,' competekttadult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the tioned case on the date and at the address indicated above. I understand that this statement is made subject to e pe al of 18 Pa. C.S. 904ing to unsworn falsifieationko authorities. NOT SERVED On the dayof 20 , at o'clock . M., I, state that Defendnt NOT FOUND because: Vacant Does Not Exist Moved , a competent adult hereby •Does Not Reside (Not Vacant) • No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: AFFIDAVTI' OF SERVICE CUMBERLAND COUNTY PH # 926710 SERVICE TEAM/ lxh COURT NO.: 13 -6566 -CIVIL PLAINTIFF JPMORGAN CHASE BANK, NATIONAL ASSOCIATION DEFENDANT WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS DEBRA D. DANGLO-GRIFFIS A/K/A DEBRA DANGLO-GRIFFIS SERVE WESLEY F. GRIFFIS A/KJA WESLEY GRIFFIS AT: 338 B ST CARLISLE, PA 17013-1824 ' • **DIVORCED- One cannot accept service for the other** SERVED Served and made known to WESLEY F. GRIFFIS A/K/A WESLEY GRIFFIS, Defendant on the 20 (4 . at Q tl✓ 4•o, o'clock 7-. M., at 33g. . STat4r, C472.uu € IPA in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is . _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. CO officer of said Defendant's company. Other: �-�C1- 1779•NT Description: Age 3Cc Height ,b�S Weight 100 Race W, Sex t— Other r.R_on a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 day of b& EMeg.,2 DATE: _1, P.64 NAME: PRINTED NAME: �ti0111I(iIVI011 Process Server TITLE: NOT SERVED On the day of ;20' , at o'clock — M., I,' , a competent adult hereby state that Defendant NOT FOUND because: Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other. I. understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: • PRINTED NAME: