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Home My WebLink About13-6743 Supreme Court of Pennsylvania 4cou11: rtl Coin" Pleas ��'I ilk Etl et For Prothonotary L's,- Chats{: Cu�bberland Count~ l o st : !! The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S`' ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E , Lead Plaintiff Name: Lead Defendant's Name: JPMORGAN CHASE BANK, NATIONAL YING FEI MOLLICA C ASSOCIATION CHARLES J. MOLLICA I Dollar Amount Requested within arbitration limits 0 Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits 1' Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff /appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se) Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Employment dispute: ❑ Statutory Appeal: Other E mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑Employment Dispute: Other T ❑ Other: I_ 0` MASS TORT ❑Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort -Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABFL7 ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin • Medical • Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. - SUITE 5000 -BNY MELLON INDEPENDENCE CENTER " t 701 MARKET STREET " PHILADELPHIA, PA 19106 (866) 413 -2311 _ i ,_ + • U JPMORGAN CHASE BANK, NATIONAL ;' i ''j `" t t�' " OURT OF COMMON PLEAS ASSOCIATION `L f c/o 3415 Vision Drive OF Cumberland COUNTY Columbus, OH 43219 Plaintiff CIVIL ACTION - LAW vs. YING FEI MOLLICA ACTION OF MORTGAGE FORECLOSURE CHARLES J. MOLLICA Mortgagor(s) and Record Owner(s) —ANI ,, ACTTON: MOPJ G 303 East Main Street Mechanicsburg, PA 17055 Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 00 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA Ct ft4 ' 1 o3 AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 4 CY-W 7SQLs 12W- a9P8Z/ SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http: / /www.phfa.org/ consumers /homeowners /real.q ax 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http : / /www.philadelphiafed.org /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 -413 -2311 or via email at homeretentiona ,,kmllawfzroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 126097FC. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are YING FEI MOLLICA, 303 East Main Street, Mechanicsburg, PA 17055 and CHARLES J. MOLLICA, 303 East Main Street, Mechanicsburg, PA 17055, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On November 12, 2004 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR ERA MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on November 18, 2004 as Book 1888 page 2088. The mortgage has been assigned to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION by assignment of Mortgage recorded on January 09, 2013 as Instrument 4201300841. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of October 23, 2013: Principal Balance ..................................... ............................... ....................$128,368.75 Interest from 06/01/2013 through 09/30/2013 ....................... ......................$2,567.36 Accrued Late Charges ................................ ............................... ......................$2,121.12 EscrowAdvance ........................................ ............................... ......................$1,153.57 Property Inspections .................................... ............................... ........................$280.00 Suspense Balance .............................................................. ............................... ($418.59) Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $135,722.21 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $135,722.21, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By. LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua L Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Pennsylvania Verification Shanteria D. Davis , hereby states that he /she is Vice President of 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 falsification to authorities. Shanteria D. Davis Vice President Date: 1 I • S• 13 JPMorgan Chase Bank, N.A Borrower: ut4x -o' _ I''u"""" Property Address: 3 ! County: Last Four of Loan Number: '5 5 53 E�h i 6 i tA ALL THAT CERTAIN Tract or parcel of land situate in the Borough of Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northerly side of East Main Street, which point is fifty -fire (55) feet East of the Northeasterly comer of North Walnut Street and East Main Streets; thence through the center of a partition wall and beyond, North 19 degrees 30 minutes 00 seconds West, one hundred sixty and zero one- hundredths (160.00) feet to a point on the Southerly line of Strawberry Alley; thence along same North 63 degrees 14 minutes 00 seconds East ` 39.5 feet to a point; "thence South 19 degrees 30 minutes East, one hundred sixty -five and zero one- hundredths (165.00) feet to a point on the Northerly side of East Main Street aforesaid; thence along same South 70 degrees 30 minutes 00 seconds West, thirty -six and seventeen one - hundredths (36.17) feet to a point, the place of BEGINNING. BEING THE SAME PREMISES which Joseph G. Nadzom and Pamela Sibley, by their deed to be recorded simultaneously herewith in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Charles J. Mollica and Ying Fei Mollica. `Erroneously set forth in prior deed as one - hundred sixty (160 feet) *'This course was erroneously omitted in prior deed. I Certify his to be rec° pA In Cnberland County P, Recorder of Deeds f 888PG21-04 Ey�,h *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5 -7734) CHASE P.O. Box 44090 1 Jacksonville, FL 32231 -4090 1 1 1111 111 7190 1075 4460 2752 2071 September 4, 2013 00012880 HDLO CC 24713 -BR860 CHARLES J MOLLICA 303 E MAIN ST MECHANICSBURG, PA 17055 Chase (FL5 -7734) CHASE P.O. Box 44120 Jacksonville, FL 32231 -4120 September 4, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00012879 HDLO ZB 24713 -BR860 CHARLES J MOLLICA 303 E MAIN ST MECHANICSBURG, PA 17055 Act 91 Notice Account: _5553 (the "Loan ") Property Address: 303E MAIN STREE MECHANICSBURG, PA 17055 (the "Property") Dear CHARLES J MOLLICA: On the following page, you will find a notice regarding your home as required by Pennsylvania law. Chase (FL5 -7734) CHASE P.O. Box 44090 Jacksonville, FL 32231 -4090 7190 1075 4460 2752 2095 September 4, 2013 00012883 HDLO CC 24713 -BR860 YING FEI MOLLICA 303 E MAIN ST MECHANICSBURG, PA 17055 Chase (FL5 -7734) CHASE P.O. Box 44120 Jacksonville, FL 32231 -4120 September 4, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 1111111 111111111111111 111111111111 1111111111111111111 111111111 00012882 HDLO ZB 24713 -BR860 YING FEI MOLLICA 303 E MAIN ST MECHANICSBURG, PA 17055 Act 91 Notice Account: =5553 (the "Loan ") Property Address: 303E MAIN STREE MECHANICSBURG, PA 17055 (the "Property ") Dear YING FEI MOLLICA: On the following page, you will find a notice regarding your home as required by Pennsylvania law. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons with impaired hearing can call 717- 780 - 1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): CHARLES J MOLLICA YING FEI MOLLICA PROPERTY ADDRESS: 303E MAIN STREE MECHANICSBURG, PA 17055 LOAN ACCOUNT NUMBER: _5553 ORIGINAL LENDER: ERA MORTGAGE CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HA VE A MEETING WITHA COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE A CTION A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL Y APPRO VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at: 303E MAIN STREE, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 07/01/2013 $1,236.63 08/01/2013 $1,236.63 09/01/2013 $1,236.63 Other charges: Late Charges: $2,032.46 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $280.00 Amount Held in Suspense: $418.59 TOTAL AMOUNT PAST DUE: $5,603.76 HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,603.76, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check, certified check or money order made payable and sent to Overnight/Regular Mail: Chase Mail Code: 01-14 -7133 3415 Vision Drive Columbus, OH 43219 -6009 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon , your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) -DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by pang the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Chase Address: Mail Code: 0114 -7384 3415 Vision Drive Columbus, OH 43219 Telephone Number: 800 - 848 -9380 Fax Number: 614 - 5004605 Contact Person: Bruno Mejia E -mail Address: state .programs.intakc @jpmchase.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Advantage Credit Counseling ServicelCCCS of 888 -511 -2227 2000 Linglestown Road Harrisburg 17102 Western PA Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104 Region Housing Alliance of York1Y Housing Resources 717 - 855 -2752 290 West Market Street York 17401 Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717 -334 -1518 40 E. High Street Gettysburg 17325 Inc. PHFA 717 - 780 -3940 211 Not Front Street Harrisburg 17110 800 -342 -2397 Rev. 10112 FM646 We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and /or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military benefits and protections also may be available if you are the dependent of an eligible Servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or Military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 877 - 469 -0110. AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888 - 995 -HOPE; 888 - 995 -4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. BR860 Ey,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information Inst. # 2013DO841 - Page 1 of 3 CERTIFIED PROPERTY IDENTIFICATION NUMBERS / 18 -23 -0565 -168 - MECBANICSBURG 3 CCGIS REGISTRY 01/09/2013 BY TB E.Lance/NTC, 2100 Alt. 19 North, Palm Harbor, FL 34683 (800)346 -9152 Loan #: =553 Tax lIttCDIdff i e/PIN/UPI #: 1II8]]- 23- 0565 -168 IIII'' II ll ! ASSIGNMENT OF MORTGAGE Contact JPMORGAN CHASE BANK, N.A. for this instrument 780 Kansas Lane, Suite A, Monroe, LA 71203, telephone # (866) 756 -8747, which is responsible for receiving payments. FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, ITS SUCCESSORS AND ASSIGNS PO BOX 2026, FLINT, MI, 48501 (HERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) by these presents does convey, grant, assign, transfer and set over the dosctibed Mortgage therein together with all interest secured thereby, all bens, and any rights due or to become due thereon to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)756 ITS'SUCCESSORS OR ASSIGNS, (ASSIGNEE). Said Mortgage is dated 11/12f2004, in the amount of $147,920.00, made by CHARLES J. MOLLICA AND YING FEI MOLLICA to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ERA MORTGAGE, recorded on 11/1&'2004, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1888, Page 2088, and/or Document # n1a. . Property is commonlyy known as: 303 EAST MAIN STREET BORO.OF MECHANICSBURG, MECHANICSBURG, PA 17055. Dated on 12 / 1 D —12013 (MMIDDWYYY) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, ITS SUCCESSORS AND ASSIGNS ASST. SECRETARY PAGE I JPCAS 18653544 -0 CHASE 014526679 N I MIN 100020000293193169 MERS PHONE 1- 888-679 -6377 f 70213012515 [C) FRMPAI 1 111111 VIII VIII VIII VIII IiAI III VIII IIII III •18653544• Inst_ # 201300841 - Page 2 of 3 Loan # 553 I l llf ll lil 1111111111 IN11111111111111111111111 111111111 I STATE OF LOUISIANA PARISH OF OUACHITA J a J k S J On / I L � JZ013 (MM/DD/YYYY), before me appeared bi -S za2+ to me personally known, who did say that he/she/they is/are the ASST. SECRETARY of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, M SUCCESSORS AND ASSIGNS and that the instrument was signed on behalf of the corporation (or association), by authority from its board of directors, and that he/she/they acknowledged the instrument to be the free act and deed of the corporation (or association)_ Notary Public - State of LOUISIANA Commission expires: Upon My Death Assi of Mort from: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, ITS SUCCESSORS AND ASSIGNS PO BOX 2026, FLINT, MI, 48501 (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)756- 8747,1TS SUCCESSORS OR ASSIGNS, (ASSIGNEE) Mortgagor. CHARLES J. MOLLICA AND YING FEI MOLLICA When Recorded Return To: JPMorgan Chase Bank, NA C/O NTC 2100 Alt. 19 North Palm Harbor, FL 34683 All that certain lot or piece of ground situated in Mortgage Premise: 303 EAST MAIN STREET BORO. OF MECHANICSBURG MECHANICSBURG, PA 17055 CUMBERLAND (Borough or Township, if stated), Commonwealth of Pennsylvania. Bein more particularly described in said Mortgage. hereby certify that the below information and address for the , assignee are correct - JPMQRGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)756-8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE) By: a ASST. SECRETARY PAGE 2 *18653544* JPCAS 18653544 -@ CHASE C34526679 N MIN 100020000293193169 MERS PHONE 1 -888- 679 -6377 70213012515 [C] FRMPAI l 111111 HE 11111 11111111111111 IN I 1111 1111 *18653544* Inst. # 201300841 - Page 3 of 3 ROBERT P. ZIEGLER w;- CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 = Iff 717 -240 -6370 Instrument Number - 201300841 Recorded On 1/9/2013 At 9:28:06 AM * Total Pages - 3 • Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 126397 User ID - KW • Mortgagor - MOLLICA, CHARLES J • Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC • Customer - SM'LIFILE LC E- RECORDING * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.00 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $51.00 I Certify this to be recorded in Cumberland County PA 1 o f eu 2� N, 7 a` RECORDER OF DEEDS rsso * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. IN THE COURT OF COMMON PLEAS O CUMBERLAND COUNTY, PENNSYLV2"IA JPMORGAN CHASE BANK, NATIONAL r ca ASSOCIATION j 2 r �' C Plaintiff Case No. J J (f! vs. C'o YING FEI MOLLICA CHARLES J. MOLLICA Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully ubmitted: (Sig ture of Counsel or Plaintiff) � I fll Date 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 hest of your knowledge: G-9301al NMWMMB1 " PLO Borrower name(s): Property Address: City: State:_ Zip: Is the property for sale? Yes EJ No 0 Listing date: Price: $ Realtor Name: Realtor Phone. Borrower Occupied? YOSD No Mailing Address (if different): City: State Zip: Phone Numbers: Home: — fr�,: Cell: Other: Email: # of people in household: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Cell: Other: Email, # of people in household: How long? FINANCIAL INFORNIAT ION 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 [3 No If yes, provide names, location of court, rase 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 awed: 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 Fay Days: Monthly Ex ensesr (Please only include expenses you are currently Paying) EXPENSE AMOUNT EXPENSE AMOUNT MortRa e Food 2 Mort a e Utilities Car 1'avmen s Condot'Nei . Fees Auto Insurance Med. not covered ,Auto fuel7re airs Other proe. payment Install. Loan Payment Cable TV Child Su rt/Alirn. Spending Mone l�k /Child CarelTuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? 'Y'es No El If yes, please provide the following information, Counseling Agency: Counselor: Phone (Office): Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [j 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 0 If yes, please indicate the status of those negotiations: Please provide the fol lowing information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Narne): Contact: Phone: AUTHORIZATION Ywe, , authorize the above named to uselrefer this information to my lendertservicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that l/we am/are under no obligation to use the services provided by the abode 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 Y Proof of any expected income for the Last 45 days V Copy of u current utility bill Y Letter explaining reason for delinquency and any supporting documentation f (hardship letter) V Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson I _' 1- I--rr- Sheriff E : Ir07 10E'6 1 riw Jody S Smith � b�1 � xrurr[ P4*4 r Chief Deputy AN I�OV 20 W,4-- 07 Richard W Stewart CUMBEl LANID (,NOU.N-fV Solicitor OFNCEOF THE$HERIFF PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. Ying Fei Mollica (et al.) 2013-6743 SHERIFF'S RETURN OF SERVICE 11/18/2013 07:32 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: Charles James Mollica at 303 E Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. JAS Ofsl KIN16LER, DEPUTY 11/18/2013 07:42 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 Michael Kapp, boyfriend, who accepted as"Adult Person in Charge"for Ying Fei Mollica at 48 E Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. JAS014 KIKS-I-Ek, DEPUTY SHERIFF COST: $66.60 SO ANSWERS, November 19, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Tcleosoft,Inc. a Ryan A.Webber,Esquire ANDREW W.BARBIN,P.C. Atty I.D.No.309693 5 Kacey Court,Suite 102 Mechanicsburg,PA 17055 (717)506-4670 Attorney for Defendants JPMORGAN CHASE BANK,N.A. : IN THE COURT OF COMMON PLEAS OF c/o 3415 Vision Drive : CUMBERLAND COUNTY, PENNSYLVANIA Columbus, OH 43219 . Plaintiff, : vs. : n? =� t- YING FEI MOLLICA : CHARLES J. MOLLICA `•. -n 303 East Main Street > c Mechanicsburg, PA 17055 CIVIL NO. 13-6743 Defendants REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property,which is Defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. § 4904 relating to uns rn falsific do to authorities. 1lyl)Y Ryan Webber,Esquire Date App�i��ed e_. 'ep : ve for Defendants � , �� iii, I i r I en# ./ Date ■ IA. Ol D cl De ndant Date JPMORGAN CHASE BANK,N.A. : IN THE COURT OF COMMON PLEAS OF c/o 3415 Vision Drive : CUMBERLAND COUNTY, PENNSYLVANIA Columbus, OH 43219 • Plaintiff, • vs. rri ; ..._ r7`s YING FEI MOLLICA • u7 r • CHARLES J. MOLLICA 303 East Main Street Mechanicsburg, PA 17055 : CIVIL NO. 13-6743 ` ' » Defendants CASE MANAGEMENT ORDER AND NOW, this /0-4 day of , 2014, the Defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the Defendant/borrower has complied with the Administrative Rule requirements for the scheduling of 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 17hellvti 7 v2 1 at 6?Z1 `?M in &f,d/91-2/4".4-e) # at the Cumberland County Courthouse,Carlisle,Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the Defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the Defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The Defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the Plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the Plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the Plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the Plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the Plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through 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 in to 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, /7. J. n4.. f1 . rnc_kr- wI 1/coM JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION — LAW : NO. 13-6743 CIVIL YING FEI MOLLICA and CHARLES J. MOLLICA, Defendants : MORTGAGE FORECLOSURE ORDER AND NOW, this 7 day of March, 2014, at the request of counsel for the parties, the conciliation conference set for March 7, 2014, is continued to Friday, March 28, 2014, at 3:00 p.m. in Chambers of the undersigned. Nathan Wolf, Esquire For the Plaintiff ../Iyan Webber, Esquire For the Defendants :dm BY THE COURT, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION — LAW : NO. 13 -6743 CIVIL YING FEI MOLLICA and CHARLES J. MOLLICA, Defendants : MORTGAGE FORECLOSURE ORDER AND NOW, this Z B day of March, 2014, following conciliation conference, it appearing that the homeowners desire to pursue a new option with the plaintiff, a new application packet will be submitted within fourteen (14) days and a continued conciliation conference is set for Friday, May 9, 2014, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, ./Nathan Wolf, Esquire For the Plaintiff .It'yan Webber, Esquire For the Defendants :rim 0.71.€S s /iY s� Crp °1 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION — LAW : NO. 13-6743 CIVIL YING FEI MOLLICA and CHARLES J. MOLLICA, Defendants : MORTGAGE FORECLOSURE ORDER AND NOW, this / � day of May, 2014, the conciliation conference herein is continued with the understanding that the borrower will be submitting a complete HAMP package within fourteen (14) days. Continued conciliation conference is set for Friday, July 11, 2014, at 3:00 p.m. in Chambers of the undersigned. Nathan Wolf, Esquire Fo the Plaintiff Ryan Webber, Esquire For the Defendants :rim frIA,,-Lck BY THE COURT, Kevi A. Hess, P.J.