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Home My WebLink About13-7557 Supreme Court of Permsylvania ,�''� ` - , Couf of Common Pleas Coil II' C Sheet For �Paotltonotary Use, Onit': i cumberlAnd County plc: F The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: JPMORGAN CHASE BANK, NATIONAL VICKI A. EDDY C ASSOCIATION KEVIN M. EDDY T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A J 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 11 Other El 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 B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin • Medical • Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET C F i f i IA R y PHILADELPHIA, PA 19106 1 (866) 413 -2311 t `j 13 DEC 2 3 AN J: 51, WWW.LU L WC:Rni1P.Com JPMORGAN CHASE BANK, NATIONAL CUi 1BER AKXI #L WT OF COMMON PLEAS ASSOCIATION PENNSYLVANIA C/O 3415 Vision Drive OF Cumberland COUNTY Columbus, OH 43219 Plaintiff CIVIL ACTION - LAW vs. VICKI A. EDDY ACTION OF MORTGAGE FORECLOSURE KEVIN M. EDDY Mortgagor(s) and Record Owner(s) CIVIL ACTION: MORTOArm 311 Walton Street FO�C'LUSURE Lemoyne, PA 17043 Defendant(s) 1 3 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA i,1b-31� AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ck M 7$4 V7 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.Dhfa.org/consumers/homeowners/real.qWx 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.philade]pliiafed.orfz/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentiongkmllaw roup.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 12689317C. 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 VICKI A. EDDY, 311 Walton Street, Lemoyne, PA 17043 and KEVIN M. EDDY, 311 Walton Street, Lemoyne, PA 17043, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On October 04, 2002 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to CENTURY 21 MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on October 08, 2002 as Book 1776 Page 2705. The mortgage has been assigned to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION by assignment of Mortgage recorded on December 03, 2007 as Instrument #200744877. 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 August 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 November 19, 2013: PrincipalBalance ...................................... ............................... .....................$55,546.47 Interest from 07/01/2013 through 10/31/2013 ....................... .......:..............$1,249.80 AccruedLate Charges ................................. ............................... ........................$130.74 EscrowAdvance ......................................... ............................... ........................$255.99 Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $58,833.00 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 $58,833.00, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW GROUP, 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 1. 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 Kathryn Coffee - House , hereby states that h 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 falsifi tion to authorities. at n o -House Vice Pre i Date: JPMorgan dha4 Bank, N.A Borrower: L(,l� 7 Property Address: � �✓ County: Last Four of Loan Number: Ey, hibitA 1 EXHIBIT "A" - MORTGAGE LEGAL ALL THAT CERTAIN lot or parcel of land situate in the Borough of Lemoyne formerly of Lower Allen Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to0wit: BEGINNING at a point on the northwesterly line of Walton Street, 1110.15 feet West from the westerly comer of Walton and Third Streets, at comer of lands now or formerly of Morris Miller, thence in a northwesterly direction r along the line of said last mentioned lands, 50 feet to a stake on line of lands now or formerly of Heisley; . thence in a southwesterly direction along the line of said last mentioned lands, 39.85 feet to a point on the northeastern line of 17.8 foot alley; thence southeastwardly by the line of said alley, 50 feet to Walton Street; thence nouheastwardly along Walton Street, 39.85 feet to a point, the place of beginning. HAVING THEREON ERECTED a single one story frame dwelling house known and numbered as 311 Walton Street, Lemoyne, PA. PARCEL NO. 12 -22- 0822 -211 S i i i i i I - (Eddy.PWEDDYl15) $K 1770FS272 Eyt,.,h *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5 -7734) Ll A S E , P.O. Box 44090 1 f �._HA O Jacksonville, FL- 32231 -4090 7190 1075 4460 2730 4653 August 30, 2013 00034428 HDLO CC 24213 -BR860 - KEVIN M EDDY 311 WALTON ST LEMOYNE, PA 17043 Chase (171-5 -7734) P.O. Box 44120 CHASE Jacksonville, FL 32231 -4120 August 30, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail IIIIIIIIili„.I, III ..,IIIIIIIIIII 00034426 HDLO ZB 24213 -BR860 VICKI A EDDY 311 WALTON ST LEMOYNE, PA 17043 Act 91 Notice Account: _8846 (the "Loan ") Property Address: 311 WALTON ST LEMOYNE, PA 17043 (the 'Property") Dear VICKI A EDDY: 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 NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): KEVIN M EDDY VICKI A EDDY PROPERTY ADDRESS: 311 WALTON ST LEMOYNE, PA 17043 LOAN ACCOUNT NUMBER: _8846 ORIGINAL LENDER: CENTURY 21 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 (331 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 APPLICA TION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH CO UNSELING A GENC Y WITHIN THIRTY-THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTIONAGAINST 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 APPLICATIONIS EVENTUALLYAPPROVED ATANY 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: 311 WALTON ST, LEMOYNE, PA 17043 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 $594.08 08/01/2013 $594.08 Other charges: Late Charges: $87.16 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $0.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $1,275.32 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 $1,275.32, 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: 0144 -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 nay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Chase Address: Mail Code: 0114 -7384 3415 Vision Drive Columbus, OH 43219 Telephone Number: 800 - 848 -9380 Fax Number: 614 - 5004605 Contact Person: Bruno Mejia E -mail Address: state .programs.intake @jpmchase.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Advantage Credit Counseling 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 YorklY Housing Resources 717- 855 -2752 290 West Market Street York 17401 Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717 - 334 -1518 40 E. High Street Gettysburg 17325 Inc. PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110 800 -342 -2397 Rev. 10/12 FM646 We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military benefits and protections also may be available if you are the dependent of an eligible Servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or Military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 877 -469 -0110. AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan' ' distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888 - 995 -HOPE; 888 - 995 -4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. BR860 Eyhibit *Exhibit has been redacted to remove allpersonally identifiable information or non-public information PREPARED 13Y: Stewart Lender Services -` ° RECORDING REQUESTED BY /AFTER RECORDING RETURN TO: Stewart Lender services Ann. Meads LeBlanc P.O. Box 36369 Houston, Texas 77236 Tel. (600) 79&6283 Pool: 654293- Loan Number. 0020366966 Ot her Lean S' : J "S SLS 8: ' 1457" Project Number. 2322007001 (Spaeu Above this Line For Recorder's Use Only) ASSIGNMENT of MORTGAGE STATE OF PENNSYLVANIA KNOW ALL MEN BY THESE PRESENTS: COUNTY OF CUMBERLAND That CENTURY 21 MORTGAGE ('Assignor'), acting herein by and through a duly authorized officer, the owner and holoer of one certain promisspry note executed by KEVIN M EDDY AND VICKI A EDDY ('Borrower(s)l secured by a Mortgage of even date therewith executed by Borrower(s) for the benefit of the holder of the said note, which was recorded on the lot(s), or parcel(s) of land described therein situated In the County of Cumberland, State of Pennsylvania: Recording Ref: Recorded on 1018/2002, Book 1776, Page No. 2705 For and in consideration of the sum of Ten and No/100 dollars ($10.00), and other good valuable and sufficient consideration paid,.the receipt of w((ich is hereby acknowledged, does hereby transfer and assign, set over and deriver unto J.P. MORGAN CHASE BANK, NA (Assignee) all beneficial interest in and to title to said Mortgage, together with the note and all other liens against said property securing the payment thereof, and all title held by the undersigned in and to said land. TO HAVE AND TO HOLD unto said-Assigpee said above described Mortgage and note, together with all and stnpularthe liens, rights, equities, title and estate in said real estate therein described securing the payment thereof, or otherwise.. Executed thts the 31st day of October A.D. 2007. CENTURY 21 MORTGAGE By. -� - JAMES UCHERKA VICE PRESIDENT THE STATE OF TEXAS COUNTY OF HARRIS On this the 31st day of October A.D. 2007, before me, a Notary Public, appeared JAMES KUCHERKA to me personally known, who being by me duly swum, did say that (s)he is the VICE PRESIDENT of CENTURY 21 MORTGAGE, and that said Instrument was signed on behalf of said corporation by authority of its Board of Directors, and said JAMES KUCHERKA acknowledged said instrument to be the free act and deed of said corporation. IN WITNESS WHEREOF, I have hereunto set my hand and affokedpy official sea_ I the day and year first above written. I DO CERTIFY THAT THE PRECISE RESIDENCE OF THE WITHIN ASSIGNEE IS: Assignee's Address: Assignor's Address: 194 Wood Avenue)39ulh 3000 Leaden hall Road Iselin NJ 08830 ML Laurel, NJ 08054, Marl Stop LGL, Attention: General Counsel On behalf of Assignee Ce :GAYLECRADN4E TARY PUBLIC TE OF Tr xgS XPIRES 0891 -2010 I��l 9 6 I�IU I��Il��ll�ldl��Q�ll��lpl�9�ll�ll9lA��NI�II�gB ROBERT P. ZIEGLER RECORDER OF DEEDS s, CUMBERLAND COUNTY 1 COURTHOUSE SQUARE ' — ter CARLISLE, PA 17013 - 717- 240 -6370 Instrument Number - 200744877 Recorded On 12/3/2007 At 11:51:44 AM * Total Pages - 2 _ * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 9935 User ID - KW * Mortgagor - CENTURY 21 MORTGAGE * Mortgagee - J P MORGAN CHASE BANK NA * Customer. - STEWART LENDERS SERVICES * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $10.00 JUSTICE DO NOT DETACH RECORDING FEES — $11.50 RECORDER OF DEEDS COUNTY ARCHIVES FEE $2.00 This page is now part ROD ARCHIVES FEE $3.00 of this legal document. TOTAL PAID $27.00 I Certify this to be recorded in Cumberland County PA O C M RECORDER 0JFD&D trao "- Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 000M 1111f1111111lII I� al 11 111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff Case No. _), l Y 7 VS. Co =1 VICKI A. EDDY KEVIN M. EDDY vyr— r.) Defendant(s) rte- w NOTICE OF RESIDENTIAL MORTGAGE FORECL( Rk: Sri DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court - supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: , (Signature of Counsel fo mtiff) 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 inforrnati.on to the best of your knowledge: Borrower name(s): Property Address: City: State:_ Zip: Is the property for sale? Yes EJ No LJ Listing date: Price: $ Realtor Name: _ _ Realtor Phone: Borrower Occupied? Yes D No [j Mailing Address (if different); City: State: Zip: Phone Number& Donne: 0 1 Tic e: Cell: Other: Email: # of people in household: How Iona? Mailing Address: City. State Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people i household: How long? First. Mortgage Lender: Type of Loan: Loan Number Bate You Closed Your Loan: Second Mortgage L ender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes Insurance ___.. Date of Last Payment I' ritT�3PY Reason for I3efault: Is the loan in Bankruptcy? 'Y'es No [3 If yes Provide names, location of court, case number & attorney: Assets Amount Owed: Value; Horse: $ Other Real Estate: Retirement Funds; S Investments: $ $ Checking:. $ Savings: $ $ Other: Automobile #I : Model: Year: Amount owed: Value- Automobile #2 : Model: Year. Amount €awed' Value: Other transportation Watomobiles boats Motors cles • Model Year: Amount owed: Value Montli!y Income Name of Employers: l . 2 3. Additional Income. Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days; -- -- -- _ _ _ _ ... Co- Borrower Pay Days: Monthly Exlaensesr (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE A 40UNT Nlongago, Food 2 Mott a e Utilities Car Pa ants Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs, Other pro . payment Install. - Loan Payment Cable TV Child Su rtlAllm. S endin Move Da /Child Care/Tuit. _._ .. ._ Other Expenses Amount Available for monthly h9ortgage 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: Couriselor: Phone.(Officp): 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 El If yes, please indicate the status of those negotiations; Please provide the following information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): . Contact: Phone: me, , authorize the agave named to useirefer this information to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that llwe am/are under no obligation to use the services provided by the above named Borrower Signature. Date Do- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income fast 2 bank statements rf Proof ofany expected income for the last 45 days _V[ Cope of a current utility mill Y Letter explaining reason for delinquency and any supporting documentation . (hardship letter) Listing agreenitent (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Hi., ofCari t,1 i Jody S Smith 4) Chief Deputy ?1";1',I JA!! -8 An Richard W Stewart , Solicitor w °• fi' �� t;� ; �c Lit JPMorgan Chase Bank, National Association Case Number vs. Vicki A Eddy (et al.) 2013-7557 SHERIFF'S RETURN OF SERVICE 12/30/2013 07:19 PM - Deputy Shawn Harrison, being duly sworn according to law, served t►- equested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint i . •a.- .reclosure by "personally" handing a true copy to a person representing themselve• . •- h• I= endant, to wit:Vicki A Eddy at 311 Walton Street, Lemoyne Borough, Lemoyne, PA 17043. S =t!N H DEPUTY 12/30/2013 07:19 PM - Deputy Shawn Harrison, being duly sworn according to law, - - 'ted .ery e to the Defendant, to wit: Kevin M Eddy at 311 Walton Street, Lemoyne Borou. - by -, P• 17043.The Defendant was found to be deceased. SH• '1' r�'�ISO TY SHERIFF COST: $62.08 SO ANSWERS, December 31, 2013 RONN ANDERSON, SHERIFF KML Law Group, P.C. zr {'�0 > W 0TAir i By: Michael T. McKeever ""JAN 24 AH 1J: S2 Attorney I.D. #56129 0U{48E Suit 5000 BNY Independence Center PENlUS YL COUNTY Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL IN THE COURT OF COMMON ASSOCIATION PLEAS OF Plaintiff Cumberland COUNTY vs. CIVIL ACTION - LAW VICKI A. EDDY and KEVIN M. EDDY ACTION OF MORTGAGE Mortgagor(s) and Record Owner(s) FORECLOSURE 311 Walton Street Term Lemoyne, PA 17043 No. 13-7557 Defendant(s) SUGGESTION OF DEATH It is respectfully suggested that Defendant Kevin M. Eddy is deceased, having departed this life on March 14th 2009. Accordingly, as Defendants owned the property which is the subject of this Action of Mortgage Foreclosure as husband and wife, by operation of law, title vests solely in Vicki A. Eddy. By: KML 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 I. Goldman Pa. 205047 Jill P' Jenkins Pa. ID 306588 Alyk Oflazian Pa ID 312912 Attorneys for Plaintiff In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY (Mortgagor(s) and Record Owner(s)) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against VICKI A. EDDY by default for want of an Answer. Assess damages as follows: Debt Interest from 11/1/2013 to Date of Sale per diem at $10.27 Total (Assessment of Damages attached) $58,833.00 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1, 1 T By: KML LAW RO ',P.'. Michael M ever ' a. ID 56129 _Jay E. Kivi. a. 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. 205047 Jill P. Jenkins Pa. ID 306588 Andrew 7 orn Pa. 92382 -�1lKo ne s or taintif£ L 300 AND NOW 1 1 , I udgme t is entered in favor of JPMORGAN CHASE BANK, ATIONAL ASSOCIATION and against VICKI A. ED E = by de It for sy t of an Answer and damages assessed in the sum of $58,833.00 as per the above certification. Prothonot ov g I ID pct L_w 14.331 Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS ' OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 VICKI A. EDDY (Mortgagors and Record Owner(s)) 311 Walton Street Lemoyne, PA 17043 Plaintiff VS. Defendant(s) No. 13-7557 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothonotary By: If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 1268931:C THIS LAW 14 IRM 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. T VICKI A. EDDY EDDY, VICKI A. 311 Walton Street Lemoyne, PA 17043 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. VICKI A. EDDY (Mortgagor(s) and Record Owner(s)) 311 Walton Street Lemoyne, PA 17043 Defendant(s) DATE OF THIS NOTICE: March 10, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13 -7557 TO: VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 - IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND HIE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBI.F PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 By: A !CIVIL LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jilt P. Jenkins Pa. ID 306588 p Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Michael J. Coskey Pa ID 311835 215 -627 -1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff VS. VICKI A. EDDY NO. 13 -7557 Defendant(s) VERIFICATION OF NON - MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ( "DMDC ") website operated by the United States Department of Defense ( https:// www. dmdc .osd.mil/appj /scra/scraHome.do) for the following individual(s): VICKI A. EDDY, has a last known residence of 311 Walton Street, Lemoyne, PA 17043. The following infoiniation was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. By: KML LAW OU Michael M Ke: ver Pa. ID 56129 Lisa Lee P.. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 ,Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of : Mar -27 -2014 11:44:26 AM SCRA 3.0 Status Report Pursuant to Servicemern rs C,ivi Relief Act Last Name: EDDY First Name: VICKI Middle Name: A. Active Duty Status As Of: Mar -27 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals" active duty status based on the Active Duty Status Date Lett Active Duly Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA , No NA This response reflects where the individual left active duty status Within 367 days preceding the Active Duty Status Date The Member or HislHer Unit Was Notified of a Future Call -Up to Active Duly on Active Duly Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or histher unit has received early notification to report for active duly Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems, The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: F8UEP3471088L20 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION -C/0 3415 Vision Drive Columbus, OH 43219 VS. VICKI A. EDDY (Mortgagor(s) and Record owner(s)) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7557 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, and against VICKI A. EDDY for failure to file an Answer in the above action within (20) da s from the date of service of the Complaint, in the sum of $58,833.00. By: KML LA P.C. _.__Michael ee er Pa. ID 56129 Jay E. Kivitz Pa. 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff 44011errfr4C- 3/(71b6 I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 and that the name(s) and last known address(es) of the Defendant(s) is/are VICKI A. E Y, 311 Walton Street Lemoyne, PA 17043; By: KML W ROUP, P.C. Micha Mc eever Pa. ID 56129 Jay E. *vitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff _si 1/4,R riTatit- 3/616e ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance ._$55,546.47 Interest from 07/01/2013 through 10/31/2013 $1,249.80 Reasonable Attorney's Fee $1,650.00 Accrued Late Charges $130.74 Escrow Advance $255.99 58,833 00 AND NOW, this 13- 7557/126893FC day of By: / KML W GR 1 UP, P.C. Mic Mc eever Pa. ID 56129 Jay : ; 'vitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorn ys fo Plaintiff j *ii3ty "C ';1(16O , 2014 damages are assesses above. C Pro Prothy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION CIO 3415 Vision Drive Columbus, OH 43219 VS. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) Is? - IN THE COURT OF COMMON PECAScP . of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7557 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due 6'de, 50 pc) a 6a. os" Interest from 11/1/2013 to Date of Sale per diem at $10.27 (Costs to be added) By: $58,833.00 KML TA RO , P. Micha 1 c ever Pa. ID 56129 Jay E. itz a. ID 26769 Lisa 'a. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 sD.slcmt An ,Andrew F. Gornall Pa. ID 92382 Attorne s for Plaintiff S 0 3/6/6G 7O0? .?17 373y No. 13-7557 IN THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK, NATIONAL ASSOCIATION VS. VICKI A. EDDY ortgagor(s) and Record Owner(s)) 311 Walton Street Lemoyne, PA 17043 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group, P.C. Attorney for Plaintiff KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 ALL THAT CERTAIN lot or parcel of land situate in the Borough of Lemoyne formerly of Lower Allen Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northwesterly line of Walton Street, 1110.15 feet West from the westerly corner of Walton and Third Streets, at corner of lands now or formerly of Morris Miller; thence in a northwesterly direction along the line of said last mentioned lands, 50 feet to a stake on line of lands now or formerly of Heisley; thence in a southwesterly direction along the line of said last mentioned lands, 39.85 feet to a point on the northeastern line of 17.8 foot alley; thence southeastwardly by the line of said alley, 50 feet to Walton Street; thence northeastwardly along Walton Street, 39.85 feet to a point, the place of beginning. HAVING THEREON ERECTED a single one story frame dwelling house and numbered as 311 Walton Street, Lemoyne, PA. PARCEL NO. 12-22-0822-211 IMPROVEMENTS consist of a single one story frame dwelling house MUNICIPALITY Borough of Lemoyne BEING PREMISES: 311 Walton Street, Lemoyne, PA 17043 SOLD as the property of Vicki A. Eddy TAX PARCEL # 12-22-0822-211 BEING the same premises which John L. Strebig and Sharon L. Strebig, his wife by deed dated 10/4/2002 and recorded 10/8/2002 in Cumberland County in Deed Book Volume 253 at Page 4775 granted and conveyed unto Kevin M. Eddy and Vicki A. Eddy, his wife and the said Kevin M. Eddy departed this life on 3/14/2009, vesting title solely in Vicki A. Eddy. KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 VS. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) HE. ' F P RO Ti-10NO-TAi; f. 2014 ilPf? - AN 56 CUMBERLAND COUNTY PENNS YLV INT THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 13-7557 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: OUP, P.C. Michael ce 4 er Pa. ID 56129 JayE.Ki itP.ID26769 Lisa Lee ; . ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorney ,forggiff -311b11/-1? iCW66 KML Law Group, P.C. Suite 5000 — BNY Independence Center - 701 Market Street Philadelphia, PA 19106 215- 627 -1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY (Mortgagor(s) and Record Owner(s)) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s)- ZOii/ ?R - I A NIi: 6 CU -TER! At: 0 COUNTY IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13 -7557 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 311 Walton Street Lemoyne, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105 -2675 4. Name and address of the last recorded holder of every mortgage of record: CENTURY 21 MORTGAGE 3000 Leadenhall Road Mount Laurel, NJ 08054 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 COMMONWEALTH OF PENNSYLVANIA-DEPARTMENT OF REVENUE, INHERITANCE TAX DIVISION 1131 STRAWBERRY SQUARE 6TH FLOOR HARRISBURG, PA 17128 IN 1 bRNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITISBURGH, PA 15222 'I ENANTS/OCCUPANTS 311 Walton Street Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 3Who If By: KML L OU , P.C. Michae cKj ver Pa. ID 56129 Jay E. vitz Pa. ID 26769 Lisa e Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plajintiff yon ?/,6/66 S KM Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff t (1.14 APR -1 4[7; II JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s 3 �.�"'l�r Lit '��I 13 -7557 rj IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13 -7557 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: EDDY, VICKI A. VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 Your house at 311 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $58,833.00 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you -pay to JPMORGAN CHASE BANK, NATIONAL - ASSOCIATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215- 825 -6329 or 1 -866- 413 -2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 13 -7557 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717- 240 -6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717 - 240 -6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http: / /www.philadelphiafed .org/foreclosure / YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 13 -7557 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717 - 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215- 825 -6329 or fax 215 -825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 126893FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. VICKI A. EDDY WRIT OF EXECUTION NO 13 -7557 Civil Term CIVIL ACTION — LAW 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: $58,833.00 L.L.: Interest FROM 11/1/2013 TO DATE OF SALE PER DIEM AT $10.27 Atty's Comm: Atty Paid: $210.83 Plaintiff Paid: Date: 4/1/14 (Seal) Due Prothy: Other Costs: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: JENNIFER FRECHIE, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000 -BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 316160 KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) LEO OFF1rE PROTHON .21114 AUG t4 FH 2: 22 -UP.if3 PENNS YL, V! 126893FC CF: 12/23/2013 SD: 09/03/2014 $58,833.00 ,\tiIW THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-7557 Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by Sheriffs Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, BY: Andrew Hauck Legal Assistant to me known, who being Subscribed and sw• :. - sre me this 2'1- day of / , 20 4y . IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; et seq. Plaintiff (Petitioner) V. VICKI A. EDDY; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13-7557 Sheriff's Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint 0 Summons ❑./ Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served VICKI A. EDDY the above process on the 21 day of April, 2014, at 1:30 o'clock, PM, at 311 WALTON STREET LEMOYNE, PA 17043 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Q By handing a copy to the Defendant(s) Description: Approximate Age 51-55 Height 5'7 Weight 150 Race WHITE Sex FEMALE Hair BLONDE Military Status: ElNo [I] Yes Branch: Commonwealth/State of A; ) SS: County of arotet Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File-Number:126893FC Case ID #:3958679 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflorbach, Notary Public Washington Township, Berks County My Commission Expires November 13, 2017 KML Name and Address of Sender SUITE 5000 ROUP, P.C. 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Article Number Check type of mail or service; ❑ Certified ❑ COD ❑ Delivery Confirmation ❑ Express Mail ❑ Insured ❑ RegistereRecorded slivery (International) 0 Return Receipt for Merchandise ❑ Signature Confirmation DOMESTlG- v "x `try state, & ZIP Code) COUNTY RELATIONS OF CUMBERLAND PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF P of Child Su UBLlC WELFARE - gid Enforcement Health and Welfare P.O. Box 2675 g• - Room 432 Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Racei.t R ee ,454 Total Numbe Listed by Se PS Form 3877 February 2002 (Page 1 of 2) 126893FC Cumberland County VICKI A. EDDY Complete by Typewriter, Ink, or Ball Point Pen Sale Date: 09/03/2014 See Privacy Act Statement on Reverse KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-7557 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 311 Walton Street Lemoyne, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: CENTURY 21 MORTGAGE 3000 Leadenhall Road Mount Laurel, NJ 08054 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 COMMONWEALTH OF PENNSYLVANIA -DEPARTMENT OF REVENUE, INHERITANCE TAX DIVISION 1131 STRAWBERRY SQUARE 6TH FLOOR HARRISBURG, PA 17128 INTERNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH, PA 15222 TENANTS/OCCUPANTS 311 Walton Street Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 12, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center`r�t` L l' Q��`m'l z4 701 Market Street .f'f�Qjj�(�Q�,1+,i Philadelphia, PA 19106 2t�i AUG� 18 4 ^ 215-825-6320 Attorney for Plaintiff ��' •�` CUP�RBERL 4 PL NNS Y' Da N/A COUNT THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK, NATIONAL ASSOCIATION CIO 3415 Vision Drive of Cumberland County Columbus, OH 43219 vs. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Defendant(s) Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7557 Book: Writ: NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for September 03, 2014 at 10:00 AM in the above matter has been continued until October 01, 2014 at 10:00 AM KML LAW GROUP, P. 701 Market Street, Suit 0 0 Philadelphia, PA 19106 (215) 825-6332 Michael McKeever Pa. ID 56129 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 )C Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION C/O 3415 Vision Drive Columbus, OH 43219 vs. VICKI A. EDDY Mortgagor(s) and Record Owner(s) 311 Walton Street Lemoyne, PA 17043 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF FILING Term No. 13-7557 Book: Writ: 1 hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of Continued Sheriff's Sale in the above upon the following parties on the date listed below: VICKI A. EDDY 311 Walton Street Lemoyne, PA 17043 defendant(s) SHERIFF OF CUMBERLAND COUNTY Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 (via facsimile or e-mail) PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 (via e -filing if applicable) Date: By: CR II& KML LAW GROUP; P.C. 701 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Genevieve Mautz Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAN . C9UNTY CF THE PROTHONOTARY HONOTARY 2iir! OCTO 'AM9: 147 CUMBERLAND COUNTY PENNSYLVANIA O c ,-E 5,.14E JPMorgan Chase Bank, National Association vs. Vicki A Eddy (et al.) Case Number 2013-7557 SHERIFF'S RETURN OF SERVICE 06/17/2014 06:58 PM - Deputy Dawn Kell, 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 311 Walton Street, Lemoyne, PA 17043, Cumberland County. 08/18/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 10/01/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on October 01, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Michael McKeever on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $796.17 SO ANSWERS, October 08, 2014 RONNY R ANDERSON, SHERIFF fel. Ode_ -a.loot- et,- sz) iL pd 074 at W,,) c) CountyStl,f.e ,?ieriff, 't'eleosoft, Inc. w C- t,.. la L� On May 19, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Known and numbered as, 311 Walton Street, Lemoyne, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. LO C cr 0 Li N ate: May 19, 2014 By: CLuip Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-7557 Civil JPMORGAN CHASE BANK, NATIONAL ASSOCIATION vs. VICKI A. EDDY Atty.: Michael McKeever ALL THAT CERTAIN lot or parcel of land situate in the Borough of Lemoyne formerly of Lower Allen Township, County of Cumberland and Commonwealth of Pennsylva- nia, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northwesterly line of Walton Street, 1110.15 feet West from the westerly comer of Walton and Third Streets, at corner of lands now or formerly of Morris Miller; thence in a northwest- erly direction along the line of said last mentioned lands, 50 feet to a stake on line of lands now or formerly of Heisley; thence in a .southwesterly direction along the line of said last mentioned lands, 39.85 feet to a point on the northeastern line of 17.8 foot alley; thence southeastwardly by the line of said . alley, 50 feet to Wal- ton Street; thence northeastwardly along Walton Street, 39.85 feet to a point, the place of beginning. HAVING THEREON ERECTED a single one story frame dwelling house and numbered as 311 Walton Street, Lemoyne, PA. • PARCEL NO. 12-22-0822-211. IMPROVEMENTS consist of a sin- gle one story frame dwelling house. MUNICIPALITY Borough of Le- moyne. BEING PREMISES: 311 Walton Street, Lemoyne, PA 17043. SOLD as the property of Vicki A. Eddy. TAX PARCEL # 12-22-0822-211. BEING the same premises which John L. Strebig and Sharon L. Strebig, his wife by deed dated 10/412002 and recorded 10/8/2002 40 in Cumberland County in Deed Book Volume 253 at Page 4775 granted and conveyed unto Kevin M. Eddy and Vicki A. Eddy, his wife and the said Kevin M. Eddy departed this life on 3/14/2009, vesting title solely in Vicki A. Eddy. The Patriot -News Co. 1900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the PatriotNews 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. 2 Y 3-7557 Civil Ter JPM RGAN CHASE BA K, y NA NAL ASSOCIATI N vs. VICKI A EDDY Atty: Michael McKeever ALL THAT CERTAIN lot or parcel of land situate in the Borough of Lemoyne formerly of Lower Allen Township, County of Cumberland and nwealth of bounded and mparticularly more described as follows, to wit: BEGINNING at a point on the northwesterly line of Walton Street, 1110.15 feet West from the westerly . comer of Walton and Third Streets, at comer of lands now or formerly of Morris Miller; thence in a northwesterly direction along the line of said last mentioned lands, 50 feet to a stake u,t line of lands now or formerly of Heisley; Thence in a .southwesterly direction along the line of said last —mentioned lands, 39.85 feet to a po at on the northeaste n line of 1 byftbe alley; thence alley feet to Walton line of said . northeast`vardty along Street; thence ,,, ._ e,,�o• zaAS,feet. k4 a 0 Sworn to and This ad ran on the date(s) shown below: 07/13114 scribe -before me this 20 day of August, 2014 A.D. ry Public COMMONWEALTH OF PEND SYLVANIA NOTARIAL. SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mtg Assoc is the grantee the same having been sold to said grantee on the 1st day of October A.D., 2014, under and by virtue of a writ Execution issued on the 1st day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 7557, at the suit of JPMorgan Chase Bank N A against Vicki A Eddy is duly recorded as Instrument Number 201424917. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ( :ZA__ ,A.D. ao/V 4J 21144 19 ecorder of Deeds ecorder,�(bRDe@ds, Cumberland County, Carlisle, PA My Comii(ission Expires the First Monday of Jan. 2018 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. YLX- a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 25 day of July, 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018