HomeMy WebLinkAbout14-0225 Supreme Court o,f Peaiiisylvan a
Court on Pleas f �otnM
ForProthonotrart' Use On1t
64 "11`C Uver Sheet r ~
Cuinl \ ierindl ! . County Docket No: � #
(;Q 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 TIMOTHY A. CLARK
C ASSOCIATION CARLA J. DENTE -CLARK
T
I Dollar Amount Requested within arbitration limits
O Are money Damages requested ?: 13 Yes ® No (Check one) X outside arbitration limits
Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO
Name of Plaintiff/appellant's Attorney: KML Law Group, P.C.
❑ Check here if you are a Self-Represented (Pro Se Litigant
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Zoning Board
❑ Product Liability (does not include ❑ Statutory Appeal: Other
E mass tort) ❑Employment dispute:
❑ Slander/Libel Defamation Discrimination
❑ Other El Employment Dispute: Other
T ❑ Other:
I
Q MASS TORT ❑ Other
❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory
❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration.
❑ 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.RCP. 205.5 Updated 1/1/2011
KML LAW GROUP, P.C. RI LP - GMCf
SUITE 5000 - BNY MELLON INDEPENDENCE CENTER OF 1 H i E P
701 MARKET STREET
P HILADELPHIA, PA 19106 2 Q E 1 1 JAN — 9 A M 11 1 4
(866) 413 -2311
'y1
JPMORGAN CHASE BANK, NATIONAL ; F COMMON PLEAS
ASSOCIATION
c/o 3415 Vision Drive OF Cumberland COUNTY
Columbus, OH 43219
Plaintiff CIVIL ACTION - LAW
vs.
TIMOTHY A. CLARK ACTION OF MORTGAGE FORECLOSURE
CARLA J. DENTE -CLARK '
Mortgagor(s) and Record Owner(s) q � I S (Ut
9 Sand Pine Court No
Mechanicsburg, PA 17055 CWLAMON: MORTGAG1-
THE UNITED STATES OF AMERICA RE'O"E
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. O
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner S
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
�1L 7559>>
� > 0 (p�
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
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243 -9400.
2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling.
3). Visit HUD'S website www.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/bomeowners /real.4yx
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 homeretention@kmllawgroup.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 116880FC.
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 TIMOTHY A. CLARK, 9 Sand Pine
Court, Mechanicsburg, PA 17055 and CARLA J. DENTE- CLARK, 9 Sand Pine Court, Mechanicsburg,
PA 17055, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter
described.
3. Defendant, THE UNITED STATES OF AMERICA, is named a Defendant pursuant to 28 U.S.C.
Section 2410, and Plaintiff requests that a judicial sale be held of the Property.
4. On June 21, 2002 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter
described to WASHINGTON MUTUAL BANK, FA, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County on June 24, 2002 as Book 1762, Page 3908. The mortgage
has been assigned to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION by assignment of
Mortgage recorded on October 18, 2012 as Instrument # 201232229. 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. A loan modification agreement was executed on
December 19, 2011 and hereby attached as Exhibit D.
5. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ( "Property")
6. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for June 01, 2012 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
7. The following amounts are due to Plaintiff on the Mortgage as of December 05, 2013:
PrincipalBalance ..................................... ............................... ....................$866,256.04
Interest from 05/01/2012 through 11/30/2013 ...................... .....................$29,145.81
AccruedLate Charges ................................. ............................... ........................$404.25
EscrowAdvance ....................................... ............................... .....................$33,134.54
Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00
$930,590.64
8. 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.
9. Plaintiff is not seeking a judgment of personal liability (or an " persona m ' 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.
10. 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.
11. THE UNITED STATES OF AMERICA, the above named Defendant, has a lien filed of record, set forth
in Exhibit `E' which is attached and made part of this Complaint.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $930,590.64,
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 ortgage property.
By: '
KML LAW G ,
Michael McKeever a. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 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
Brian P. Arrington , hereby states tha he/ a 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
falsifica to thorities.
7n n
i tePresiden
Date: 12/16/13
JPMorgan Chase Bank, N.A
Borrower: TIMOTHY A CLARK & CARLA J DENTE -CLARK
Property Address: 9 SAND PINE CT, MECHANICSBURG PA 17055
County: CUMBERLAND
Last Four of Loan Number: 3416
Ext, hibit
A
All that certain tract of land situate in Hampden Township, Cumberland. County,
Pennsylvania, being Lot No. 25 as shown on the Plan entitled Pinehurst Final Subdivision
Plan Phase V; dated January 19, 1998 and recorded in Cumberland County Plan Book 76,
Page 112, more particularly bounded and described as follows:
BEGINNING at an iron pin, being an easterly corner of Lot No. 24 and lying in a
southerly right -of -way line of Sand Pine Court (50 -foot right -of -way); thence along said
right-of-way litre, South 57 degrees 42 minutes 51 seconds East, 89.41 feet to an iron pin,
being a southerly corner of said right -of -way and being a westerly corner of Sand Pine b�
Court cul-de -sac (60 foot right -of -way); thence along said right-of-way line, along a
curve to the right, having a chord beating of South 30 degrees 43 minutes 48 seconds �-
East, a chord distance of 22.69 feet, a radius of 25.00 feet, and an are length of 23.55 feet
to an iron pin; thence continuing along said right -of -way line, along a curve to the left,
having a chord bearing of South 40 degrees 46 mmutes 48 seconds East, a chord distance
of 7227 feet, a radius of 60.00 feet, and an arc length of 7756 feet to an iron pin, lying in
a southerly line of said right -oaf -way, and being a westerly corner of Lot No. 26; thence
along Lot No. 26, South 14 degrees 02 minutes {19 seconds West, 375.71 feet to an iron
pin, being a westerly corner of said lot and lying in a northerly lute of lands now or
formerly of Susquehanna Enterprises, Inc.; thence along said lands, North 77 degrees 11
minutes 41 seconds West, 160.00 feet to an iron pin, lying in a northerly line of said lands
and being a southerly comer of Lot No. 24; thence along Lot No. 24, North 14 degrees 02
minutes 09 seconds WeA, 464.90 feet to an iron pin, being the place of BEGINNING.
CONTAINING 1.560 acres.
Lot No. 25 is subject to a 10 -foot wide utility easement along its street frontage, a 30 -foot
sanitary sewer easement which traverses said Lot, a 40 -foot drainage easement centered
on a stream, 10 feet of a 35 -foot wide sanitary sewer and storm sewer easement along its
easterly boundary, and a wetland area being bounded and described as follows: --
BEGINNNING at a concrete monument, lying in an easterly line of Lot No. 24 and lying
in a westerly line of Lot No. 25; thence along said line, North 14 degrees 02 minutes 09
seconds East, 40.83 feet to a concrete monument; thence traversing through Lot No. 25,
South 65 degrees 34 minutes 29 second East, 110.28 feet to a concrete monument; thence
continuing through said lot, South 64 degrees 14 minutes 40 seconds East, 5259 feet to a
concrete monument, lying in an easterly line of said lot and lying in a westerly line of Lot
No. 26; thence along said line, South 14 degrees 02 minutes 09 seconds West, 66.11 feet
to a concrete monument; thence traversing through Lot No. 25, North 45 degrees 19
minutes 12 seconds West, 53.79 feet to a concrete monument; thence continuing through
said lot, North 60 degrees 28 minutes 43 seconds West, 95.38 feet to a concrete
monument; thence continuing through said lot, North 68 degrees 11 minutes 55 seconds
West, 21.97 feet to a concrete monument, being the place of BEGINNING.
UNDER AND SUBJECT, NEVERTHELESS, to Declaration of Pinehurst, Phase V, a
Planned Community, dated April 29, 1998 and recorded May -1, 1998 in Cumberland
County Miscellaneous Book 575, Page 376.
7f3.?.PG3925 w.
UNDER AND SUBJECT, NEVERTHELESS, to Declaration of Conservation Easement
dated April 29, 1998 and recorded May 1, 1998 in Cumberland County Miscellaneous
Book 575, Page 447.
BEING the same premises which Fred A. Tiday and Darlene J. Tiday, his wife, by their
Deed dated June , 2002 and intended to be recorded simultaneously herewith,
granted and conveyed unto Timothy J. Clark and Carla 1. Dente - Clark, his wife.
In 61 %his tO be
berI .°°
�yJ and �°��' PA --
a ,
RecOrder O DeectS
Ex �B
*Exhibit has been redacted to remove all personally identifiable information or non-public information
Chase (FL5 -7734) '-' /� S C'
PO Box 44090 CHAS GG O V
Jacksonville, FL 32231 -4090
7190 1075 4460 0848 4497
July 30, 2012
00005359 HDLG CB 21212 -BW160
CARLA J DENTE -CLARK
9 SAND PINE CT
MECHANICSBURG, PA 17055 -3079
I1111111111111111111111111111111111111111111111111111111111111
Chase (FL5 -7734) CHASE
PO Box 44090 Im '
Jacksonville, FL 32231 -4090
July 30, 2012
IIIIIIIIIIII, IIIIIIIIIIIIII
00005356 HDLO ZB 21212 -BW 160
CARLA J DENTE -CLARK
9 SAND PINE CT
MECHANICSBURG, PA 17055 -3079
Acceleration Warning (Notice of Intent to Foreclose)
Account: _3416 (the "Loan ")
Property Address: 9 SAND PINE CT
MECHANICSBURG, PA 17055 (the "Property")
Dear CARLA J DENTE - CLARK:
Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan
Chase Bank, N.A.( "Chase ") hereby notifies you of the following:
I. You are in default because you have failed to pay the required monthly installments commencing
with the payment due June 1, 2012.
2. As of July 30, 2012, total monthly payments (including principal, interest, and escrow if
applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms
of your loan documents in the total amount of $9,164.48 are past due. This past -due amount is
itemized below. If applicable, your account may have additional escrow amounts that have been
paid out and are due on the Loan. If you have any questions about the amounts detailed below,
please contact us as soon as possible at 800 - 848 -9380.
Total Monthly Payments $8,950.98
Late Fees $269.50
NSF Fees $0.00
Other Fees* $0.00
Advances* ($56.00)
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and /or permitted by applicable law, or that were authorized for services
rendered. If you need additional information regarding any of these amounts, please
contact us at the number provided below.
You are also responsible for paying any amounts that become due from the date of this letter
through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not
limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law.
Chase (FL5 -7734) CHASE
PO Box 44090 C."P
Jacksonville, FL 32231 -4090 1 1 111111 11
7190 1075 4460 0848 4503
July 30, 2012
00005358 HDLO CB 21212 -BW 160
TIMOTHY A CLARK
9 SAND PINE CT
MECHANICSBURG, PA 17055 -3079
Chase (FL5 -7734) CHASE
PO Box 44090
Jacksonville, FL 32231 -4090
7190 1075 4460 0848 4503
July 30, 2012
00005358 HDLO CB 21212 -BW160
TIMOTHY A CLARK
9 SAND PINE CT
MECHANICSBURG, PA 17055 -3079
Acceleration Warning (Notice of Intent to Foreclose)
Account: _3416 (the "Loan ")
Property Address: 9 SAND PINE CT
MECHANICSBURG, PA 17055 (the 'Property")
Dear TIMOTHY A CLARK:
Under the terms of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan
Chase Bank, N.A.( "Chase ") hereby notifies you of the following:
I. You are in default because you have failed to pay the required monthly installments commencing
with the payment due June 1, 2012.
2. As of July 30, 2012, total monthly payments (including principal, interest, and escrow if
applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms
of your loan documents in the total amount of $9,164.48 are past due. This past -due amount is
itemized below. If applicable, your account may have additional escrow amounts that have been
paid out and are due on the Loan. If you have any questions about the amounts detailed below,
please contact us as soon as possible at 800 - 848 -9380.
Total Monthly Payments $8,950.98
Late Fees $269.50
NSF Fees $0.00
Other Fees* $0.00
Advances* ($56.00)
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and /or permitted by applicable law, or that were authorized for services
rendered. Ifyou need additional information regarding. any of these amounts, please
contact us at the number provided below.
You are also responsible for paying any amounts that become due from the date of this letter
through the expiration date set forth in Paragraph 3 below. These amounts may include, but are not
limited to, taxes, insurance, inspection fees, and other fees, as permitted by applicable law.
If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is
current, please contact us at the telephone number provided below.
3. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2
within 35 days from the date of this notice in order to cure this default. All late fees, NSF fees, and
other fees and advances are still valid and will need to be repaid under the terms of your loan
documents.
4. If you fail to cure the default on or before September 3, 2012, Chase may accelerate the maturity of
the Loan, declare all sums secured by the Security Instrument immediately due and payable, and
commence foreclosure by judicial proceeding and conduct a sale of the Property. If this happens,
Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the
Security Instrument, which may include, but not be limited to, allowable foreclosure /attorney fees,
and other expenses permitted by your loan documents or applicable law.
5. If permitted by your loan documents or applicable law, you have the right to reinstate after
acceleration of the Loan and the right to assert in the foreclosure proceeding the nonexistence of a
default, or any other defense to acceleration and foreclosure. However, the amount required to
reinstate may be higher than what is owed under Paragraph 2 above, due to additional fees and
charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law,
related to any foreclosure action we initiate.
6. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed
below. Please note that Chase policy requires certified funds if two insufficient funds (NSF)
payments have been received in the last six months. In this event, Chase will not accept a Direct
Check, FastPay or SpeedPay. Payments cannot be made at Chase retail bank branches. Please refer
to the addresses below for payment information or contact us if you have any questions.
Regular Mail: CHASE
PO BOX 78420
PHOENIX AZ 85062 -8420
Overnight Mail: CHASE
PO BOX 78420
1820 EAST SKY HARBOR CIRCLE
SOUTH PHOENIX, AZ 85034 -9700
Except as required by law, we are under no obligation to accept less than the full amount owed. If
you send us less than the full amount owed, we may in our sole discretion apply such partial
payment to your Loan without waiving any default or waiving our right to accelerate the Loan and
continue with foreclosure proceedings in accordance with Paragraph 4 above.
7. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance
programs that might help you resolve your default and keep your home; however, we need to talk
with you to discuss these options and determine which of them might be appropriate for your
circumstances. Please call us as soon as possible at 800 - 848 -9380.
8. While the Loan remains in default, we will perform certain tasks to protect our interest in the
Property, including visits to your Property at regular intervals during the default. This will be done
to determine, as of the date of the inspection, the property condition, occupancy status, and possibly
your plans for curing the default and paying this Loan on time. You should anticipate that any costs
incurred by Chase will be added to the amount you now owe if permitted by your loan documents or
applicable law.
Chase offers one -on -one help to borrowers at Chase Homeownership Centers across the country. To find
locations and learn more, visit www.chase.com/MyHome or call 866 -550 -5705. Counseling is also available
through a variety of nonprofit organizations experienced in homeownership counseling and approved by the
Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by
calling HUD toll -free at 800 -569 -4287 or at www.hud.gov.
Sincerely,
Chase
800 - 848 -9380
800 -582 -0542 TDD / Text Telephone
www.chase.com
Enclosure
- Federal Trade Commission Pamphlet
Important notice to servicemembers and their dependents
If you are or recently were on active duty or active service, you may be eligible for benefits and protections
under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or
eviction. You may also be eligible for benefits and protections under state law. SCRA and state military
benefits and protections also may be available if you are the dependent of an eligible servicemember.
Eligible service may include:
• Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or
• Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or
• Active service as a commissioned officer of the Public Health Service, or
• Service with the forces of a nation with which the United States is allied in a war or military action, or
• Service with the National Guard of a state militia under a state call of duty, or
• Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause.
For more information, please call Chase Military Services at 866 - 840 -5826.
An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers
about the Homeowner Affordability and Stability Plan' distributed by the Obama Administration,
"Borrowers should beware of any organization that attempts to charge a fee for housing counseling or
modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams
should be reported to PreventLoanScams.org, or by calling 888 - 995- HOPE.; 888 - 995 -4673. We offer
loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately
at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have.
We are attempting to collect a debt, and any information obtained will be used for that purpose.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the
attorney's name, address, and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy
under Title 11 of the United States Code, this notice is for compliance and/or informational purposes
only and does not constitute an attempt to collect a debt or to impose personal liability for such
obligation. However, a secured party retains rights under its security instrument, including the right to
foreclose its lien.
BW160
An important message from the Federal Trade Commission
A note to
Homeowners
Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be
able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The
Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid
scams that could make your housing situation go from bad to worse.
Don't Get Hit by a Pitch. Imitations = Frustrations.
"We can stop your foreclosure!" Some con artists use names, phone numbers, and
"97% success rate!" websites to make it look like they're part of the
"Guaranteed to save your home!" government. If you want to contact a government
These kinds of claims are the tell-tale signs of a agency, type the web address directly into
foreclosure rip -off. Steer clear of anyone who offers your browser and look up any address you aren't
an easy out. sure about. Use phone numbers listed on agency
websites or in other reliable sources, like the Blue
Don't Pay for a Promise. Pages in your phone directory. Don't click on links
Don't pay any business, organization, or person or open any attachments in unexpected emails.
who promises to prevent foreclosure or get you a
new mortgage. These so -called "foreclosure rescue Talk to a HUD - Certified
companies" claim they can help save your home, Counseling Agency — For Free.
but they're out to make a quick buck. Some may If you're having trouble paying your mortgage or
request hefty fees in advance — and then stop you've already gotten a delinquency notice, free
returning your calls. Others may string you along help is a phone call away. Call 1 -888- 995 -HOPE
before disclosing their charges. Cut off all dealings for free personalized advice from housing counseling
if someone insists on a fee. agencies certified by the U.S. Department
of Housing and Urban Development (HUD).
Send Payments Directly. This national hotline — open 24/7 - is operated
Some scammers offer to handle financial by the Homeownership Preservation Foundation,
arrangements for you, but then just pocket your a nonprofit member of the HOPE NOW
payment. Send your mortgage payments ONLY to Alliance of mortgage industry members and
your mortgage servicer. HUD - certified counseling agencies. For free
guidance online, visit www.hopenow.com. For
Don't Pay for a Second Opinion. free information on the President's plan to help
Have you applied for a loan modification and been homeowners, visit
turned down? Never pay for a "second opinion." www.makinghomeaffordable.gov.
0 Federal Trade Commission
1-9- ftc.gov/MoneyMatters
Call
1-888-995-HOPE
for free personalized guidance from housing counseling agencies certified
by the U.S. Department of Housing and Urban Development. The
Homeowner's HOPETM Hotline — open 24/7 — is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD- certified counseling agencies. Or visit
www. hopenow.com
For free information on the President's plan to help homeowners, visit
www.makinghomeaffordable.gov
XXX HOPENOW
Support& Guidantefor Homeowners
SM
MAKING HOME AFFORDABLE.GOV
Exhibit
C
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE .�
CARLISLE, PA 17013
- ° x '
717 - 240 -6370
Instrument Number - 201232229
Recorded On 10/18/2012 At 12:25:04 PM * Total Pages - 3
Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 120007 User ID - JM
*Mortgagor - CLARK, TIMOTHY A
* Mortgagee - FEDERAL DEPOSIT INSURANCE CORP
*Customer -NATIONWIDE TITLE CLEARING
FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $11.50
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 $50.50
I Certify this to be recorded
in Cumberland County PA
ay uv cu�yeF
RECORDER O D EDS
rrso
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
002SK3
III Illlllllllflllllllllll111
G h
Prepared By / Return To:
E.Lance/NTC, 2100 Alt. 19 North,
Palm Harbor, FL 34683 002S K3
(86e)34P-9152
Loan W416
Tax Code/P :10 -14 -0842 -167
[11[11 IDII Illll 1111111111 II111 IIIII IllEl 1111111111111[ III[
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
undersi ed, FEDERAL DEPOSIT INSURANCE CORPORATION, AS RECEIVER OF WASHINGTON
MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK,FA, %Y6SE ADDRESS IS 700 Kansas Lane,
MC 8000 MONROE, LA, 71203, (ASSIGNOR), by these presents does convey, grant, assign, transfer and set
over the described Mort�ggagge therein together with all interest secured thereby, all liens, and any rights due or to
become due thereon to JP ORGAN CHASE BANK NATIONAL ASSOCIATION WHOSE ADDRESS IS
700 Kansas Lane, MC 8000, MONROE, LA 71263 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS,
(ASSIGNEE).
Said Mortgage dated 06/21/2002, in the amount of $1,000,000.00 made by TIMOTHY A. CLARK AND
CARLA J. DENTE -CLARK to WASHINGTON MUTUAL BANK, FA recorded on 06124/2002, in the Office
of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1762, Page 3908 (or Document #
n/a)
Property more commonly known as: 9 SAND PINE COURT TWP. OF HA.MPDEN, MECHANICSBURG, PA
17055
This Assignment is made without recourse, representation or warranty, express or implied, by the FDIC in
its corporate capacity or as Receiver.
This Assignment is intended to further memorialize the transfer that occured by operation of law on
September 25, 2008 as authorized by Section 11(d)(2)(G)(i)(II) of the Federal Deposit Insurance Act, 12
U.S.C. S1821(d)(2)(G)(i)(H)
JPCAS 17711149 -0 WAMU CJ42226631X Nl 12812093917 [C] FRMPAl JPCAS3
111111111111111111111111111111 11 lllllIIIII 11111111
*17711149*
�N
N
J
Loan #: =416
IN WITNESS WHEREOF this Assignment is executed on Of /2 012 (MMMD/YYYY)
FEDERAL DEPOSIT INSURANCE CORPORATION, AS RECEIVER OF WASHINGTON MUTUAL
BANK F/K/A WASHINGTON MUTUAL BANK,FA, by JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, its Attorney -in -Fact (POA RECORDED: 09/20/2012 INSTR #: 201228828)
By:
I / z s' VICE PRESIDENT
STATE OFLOUISIANA PARISH OF OUACHITA j/ G � r � t � '
On 111 1 1 2012 (MM/DD/YYYY), before me appeared & A /
to me personally known, who did say that he/she/they is/are the VICE PRE 1DENT of JPMORGAN CHASE
BANK, NATIONAL ASSOCIATION as Attorney -in -Fact for FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER OF WASHINGTON MUTUAL BANK RK/A WASHINGTON MUTUAL
BANK,FA and that the instrument was signed on behalf of the corporation (or association), by authority from its
board of directors, and that helshelthey acknowledged the instrument to be the free act and deed of the corporation
(or association).
, � ` dp515�t7t /ry,
C L S t ,S {7070 s
Notary Public - State bf LOUISIANA
Commission expires: Upon My Death
Assignment of Mortgage from:
FEDERAL DEPOSIT INSURANCE CORPORATION, AS RECEIVER OF WASHINGTON MUTUAL
BANK F/K/A WASHINGTON MUTUAL BANK,FA, WHOSE ADDRESS IS 700 Kansas Lane, MC 8000,
MONROE, LA, 71203, (ASSIGNOR),
to:
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 Kansas Lane, MC
8000, MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE)
Mortgagor: TIMOTHY A. CLARK AND CARLA J. DENTE -CLARK
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: 9 SAND PINE COURT TWP. OF HAMPDEN
MECHANICSBURG, PA 17055
CUMBERLAND
(Borough or Township, if stated), Commonwealth of Pennsylvania.
Being more particularly f �described in said Mortgage.
I, &� V y `;^� d t coo -� . ,do certify that the precise address of the within named assignee
is:
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 Kansas Lane, MC
8000, MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE)
By
Mt I Il VICE PRESIDENT
*17711149* JPCAS 17711149 -0 WAMU CJ42226631X NI T2812093917 [C] FRMPAI—JPCAS3
1111111 IIiII 11111 Illll hill 11111 VIII Ilili 1111 IIII •
*17711149*
Eyhibit (D
*Exhibit has been redacted to remove all personally identifiable information or non-public information
OIL-
Loan Number IW416
LOAN MODIFICATION AGREEMENT
Borrower ( "1) TIMOTHY A CLARK and CARLA J DENTE -CLARK
Lender ( "Lender's: JPMORGAN CHASE BANK, N.A.
Date of First Lien Security Instrument (the "Mortgage ") and Note (the "Note'): JUNE 21, 2002
Loan Number: 78093416 (the "Loan ")
Property Address: 9 SAND PINE CT, MECHANICSBURG, PENNSYLVANIA 17055 (the "Property)
If my representations in Section 1 continue to be true in all material respects, then the provisions of
Section 2 of this Loan Modification Agreement ( "Agreement ") will, as set forth in Section 2, amend and
supplement (I) the Mortgage on the Property, and (ii) the Note secured by the Mortgage.
The Mortgage and Note together, as may previously have been amended, are referred to as the "Loan
Documents." Capitalized terms used in this Agreement have the meaning given to them in the Loan
Documents.
I have provided confirmation of my financial hardship and documents to permit verification of all of my
income to determine whether I qualify for the offer described in this Agreement. This Agreement will
not take effect unless and until the Lender signs it.
1. My Representations. I represent to the Lender and agree:
A. I am experiencing a financial hardship, and as a result, am either in default under the Loan
Documents or a default is imminent.
B. The Property is neither in a state of disrepair, nor condemned.
C. There has been no change in the ownership of the Property since I signed the Loan
Documents.
D. I am not a party to any litigation involving the Loan Documents, except to the extent I may be
a defendant in a foreclosure action.
E. 1 have provided documentation for all income that I earn.
F_ All documents and information 1 provide pursuant to this Agreement are true and correct.
2. The Modification. The Loan Documents are hereby modified as of FEBRUARY 01, 2012 (the
"Modification Effective Date"), and all unpaid late charges are waived. The Lender agrees to
suspend any foreclosure activities so long as I comply with the terms of the Loan Documents, as
modified by this Agreement. The Loan Documents will be modified, and the first modified
payment will be due on the date set forth in this Section 2:
A. The Maturity Date will be: JANUARY 01, 2052.
B. The modified principal balance of my Note will include all amounts and arrearages that will be
past due (excluding unpaid late charges) and may include amounts towards taxes, insurance,
t If there is more than one Borrower or Mortgagor executing this document, each is refcrred to as "I ". For purposes of this document words
signifying the singular (such as "I ") shall include the plural (such as "we'7 and vice versa where appropriate.
WF101 V2 2 -23-10 LOAN MODIFICATION AGREEMENT -CHAMP ver. 12 08_2011_11 02 59 Page 1 of 6 pages
�� �i'Ylrlid'��YN Jif i + �5ir :II�N {�IaM1rfl II �II
Loan Number =416
or other assessments. The new principal balance of my Note is $870,889.17 (the "New
Principal Balance7.
C. The Interest Bearing Principal Balance will re- amortize over 480 months.
Interest will begin to accrue as of JANUARY 01, 2012. The first New monthly payment on the
New Principal Balance will be due on FEBRUARY 01, 2012, and monthly on the same date
thereafter.
My payment schedule for the modified Loan is as follows:
I promise to pay monthly payments according to the following schedule with respect to the
New Principal Balance.
Years Interest Interest Monthly Payment Number of
Rate Rate Principal Begins on Monthly
Change & Interest Payments
Date Payment
Amount
1 -5 2.125% 01/01/2012 $2,694.91 02/01/2012 60
6 3.125% 01/01/2017 $3,126.99 02/01/2017 12
7-40 4.000% 01/01/2018 $3,523.88 02/01 /2018 408
The Lender will notify me of the payment amount prior to the date that the monthly payment
on the Interest Bearing Principal Balance will change.
The above terms in this Section 2.0 shall supersede any provisions to the contrary in the
Loan Documents, including but not limited to provisions for an adjustable or step interest rate.
D. I agree to pay in full (i) the New Principal Balance, and (ii) any other amounts still owed under
the Loan Documents, by the earliest of the date I sell or transfer an interest in the Property,
subject to Section 3.E below, the date I pay the entire New Principal Balance, or the Maturity
Date.
E. I will be in default if I do not () pay the full amount of a monthly payment on the date it is due,
or (i) comply with the terms of the Loan Documents, as modified by this Agreement. if a
default rate of interest is permitted under the Current Loan Documents, then in the event of
default, the interest that will be due on the New Principal Balance will be the rate set forth in
Section 2.C.
3. Additional Agreements. 1 agree to the following:
A. That this Agreement shall supersede the terms of any modification, forbearance, or
workout plan, if any, that 1 previously entered into with the Lender.
B. To comply, except to the extent that they are modified by this Agreement, with all
covenants, agreements, and requirements of the Loan Documents including my
WF101 V2 2 -23-10 LOAN MODIFICATION AGREEMENT -CHAMP ver. 12 OB 2011_11_02_59 Page 2 of 6 pages
JLW W%
Loan Number W416
agreement to make all payments of taxes, insurance premiums, assessments, impounds,
and all other payments, the amount of which may change periodically over the term of my
Loan. This Agreement does not waive future escrow requirements. If the Loan includes
collection for tax and insurance premiums, this collection will continue for the life of the
Loan.
C. That the Loan Documents are composed of valid, binding agreements, enforceable in
accordance with their terms and are hereby reaffirmed.
D. That all terms and provisions of the Loan Documents, except as expressly modified by
this Agreement, remain in full force and effect; nothing in this Agreement shall be
understood or construed to be a satisfaction or release in whole or in part of the
obligations contained in the Loan Documents; and that except as otherwise specifically
provided in, and as expressly modified by, this Agreement, the Lender and I will be bound
by, and will comply with, all of the terms and provisions of the Loan Documents.
E. That, as of the Modification Effective Date, notwithstanding any other provision of the
Loan Documents, I agree as follows: If all or any part of the Property or any interest in it is
sold or transferred without the Lender's prior written consent, the Lender may, at its
option, require immediate payment in full of all sums secured by the Mortgage. However,
the Lender shall not exercise this option if federal law prohibits the exercise of such option
as of the date of such sale or transfer. If the Lender exercises this option, the Lender
shall give me notice of acceleration. The notice shall provide a period of not less than
thirty (30) days from the date the notice is delivered or mailed within which I must pay all
sums secured by the Mortgage. If I fail to pay these sums prior to the expiration of this
period, the Lender may invoke any remedies permitted by the Mortgage without further
notice or demand on me.
F. That, as of the Modification Effective Date, a buyer or transferee of the Property will not be
permitted, under any circumstance, to assume the Loan. In any event, this Agreement
may not be assigned to, or assumed by, a buyer of the Property.
G. If any document is lost, misplaced, misstated, or inaccurately reflects the true and correct
terms and conditions of the Loan Documents as amended by this Agreement, within ten
(10) days after my receipt of the Lender's request, I will execute, acknowledge, initial, and
f deliver to the Lender any documentation the Lender deems necessary to replace or
I correct the lost, misplaced, misstated or inaccurate document(s). If I fail to do so, I will be
liable for any and all loss or damage which the Lender reasonably sustains as a result of
my failure.
H. All payment amounts specified in this Agreement assume that payments will be made as
scheduled.
I. If the Borrower(s) received a discharge in a Chapter 7 bankruptcy subsequent to the
execution of the Loan Documents, the Lender agrees that such Borrower(s) will not have
personal liability on the debt pursuant to this Agreement.
J. That in agreeing to the changes to the original Loan Documents as reflected in this
Agreement, the Lender has relied upon the truth and accuracy of all of the representations
made by the Borrower(s), both in this Agreement and in any documentation provided by or
WF101 V2 223 -10 LOAN MODIFICATION AGREEMENT -CHAMP ver. 12_08_2011_11 02_59 Page 3 of 6 pages
MR UNI&L
Loan Number ■3416
on behalf of the Borrower(s) in connection with this Agreement. If the Lender
subsequently determines that such representations or documentation were not truthful or
accurate, the Lender may, at its option, rescind this Agreement and reinstate the original
terms of the Loan Documents as if this Agreement never occurred.
K. 1 acknowledge and agree that if the Lender executing this Agreement is not the
current holder or owner of the Note and Mortgage, that such party is the authorized
servicing agent for such holder or owner, or its successor in interest, and has full power
and authority to bind itself and such holder and owner to the terms of this modification.
THIS WRITTEN LOAN AGREEMENT REPRESENTS THE FINAL AGREEMENT BETWEEN THE
PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR,
CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE
ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES.
(SIGNATURES CONTINUE ON FOLLOWING PAGES)
WF101 V22-23-10 LOAN MODWICAT {ON AGREEMENT -CHAMP ver. 12 08 2011_11 02 59 Page 4 of pages
Loan Number I416
TO BE SIGNED BY BORROWER ONLY
BORROWER SIGNATURE PAGE TO MODIFICATION AGREEMENT BETWEEN JPMORGAN CHASE
BANK, N.A. And TIMOTHY A CLARK and CARLA J DENTE - CLARK, LOAN NUMBER 78093416 WITH A
MODIFICATION EFFECTIVE DATE OF February 01, 2012
In Witness Whereof, the Borrower(s) have executed this agreement.
A � Cal Date: Zi 1
Borrower - TIMOTHY A CLARK j
�a Date:
Borrower- CARLA J DENT -CLARK
WF101 V2 2 -23-10 LOAN MODIFfCATION AGREEMENT -CHAMP ver. 12 0$_2011_11_02 59 Page 5 of 6 pages
Loan Number 416
TO BE SIGNED BY LENDER ONLY
LENDER SIGNATURE PAGE TO MODIFICATION AGREEMENT BETWEEN JPMORGAN CHASE BANK,
NA. And TIMOTHYA CLARK and CARLA J DENTE - CLARK, LOAN NUMBER 78093416 WITH A
MODIFICATION EFFECTIVE DATE OF Febnjary 01, 2012
In Witness Whereof, the Lender has executed this Agreement.
Lender
JPMORGAN CHASE BANK, N.A.
B y : Claudio Gamboa
Date: Vice President
✓S/ f
WF101 V2 2 -23-10 LOAN MODIFICATION AGREEMENT- CHAMP per. 12 06_2011_11 02 59 Page 6 of 6 pages
III NOV.
kNOMIA?L'ti1 '����
E�hibit E
11883 -�-
Department of the Treasury - Internal Revenue Service
Forst 668 (Y)(c) Notice of Federal Tax Lien
(Rev. February 2004%
Area' Serial Number For Optional Use by Recording office
SMALL 13US /SELF EMPLOYED AREA f#2
Lien Unit Phone. (800) 913 -6050 782227011
As provided by section 6321, 6322, and 6323 of the Intent Revenue
Code, we are giving a notice that taxes (hwkding interest and penalties) d -'
have been assessed against the following -named taxpayer. We have made o �
a demand for payment of this iiabBity, but it remains unpaid. Therefore, zM 3 �rn
there is a Non in favor of the United States on all Property and rights to
property belonging to this tmcpayer for lice amount of these taxes, and
additional penalties, interest, and costs that may accrue. `o
Name of Taxpayer TIMOTHY CLARK
7`1 .�.
rn
c.
Residence 9 SAND P INE COLT
MECHANICSBURG, PA 17050 -0000
IMP :"day T RELEASE MFORMATION: For each assessment listed below,
unless of the lien is refiled by the date given in cotumn (e), this notice shall, /q, 90 )Ad I
on thfollowing such date, operate as a certificate of release as defined
M IRC (a). - a s9ot,
Tax Period Date of last Day for Unpaid Balance --
Kind of Tax Ending Identifying Number Assessment Refilling of Assessment
(a) (b) c (d) (e (f)
1040 12/31/2009 XXX -XX -5346 04/18/2011 05/18/2021 174233.56
Place of Filing �-
Prothonotary
Cumberland County Total $ 174233.56
Carlisle, PA 17013
,
This notice was prepared and signed at DE TROI T, M on this __ __�_ - -•— ,
the 03rd day of May 2011
Signature Title
REVENUE OFFICER 22 -06 -1441
for DENNIS P ZMUDZIN (717) 777 -9624
(NOTF- Certificate of officer authorized by law to take acknowledgment is not essential to the validity of Notice of Federal Tax lien
Rev. Rul. 71-466,1971 - 2 C.B. 449) Form 668(Y)(c) (Rev_ 2 -2004)
Pat t - Kept By Rewdhtg Office CAT. NO 60025X
mw
2447
Form etas MW Department of the Treasury - Internal Revenue Service
Notice of Federal Tax Lien
(Rev. February zco41 10 - 2t431 M
Area: Serial Number For optional use by Recorddfng office
S MALL Bt 9=9S /SELF EMPLOYED AREA #2
Lien Unit Phone (800) 913 -6050 639638310 4Iq, PO PLFF
As provided by section 6321, 6322, and 6323 of die Internal Revenue
Code, we are gh&g a notice that taxes (including Interest and penalties) OF Ae10 3S3
have been assessed against the fol[oaruir mmed taxpayer. We have made
a dound for payment of this liabiElty, but it remains unpaid. Therefore,
there is a lien in favor of the United States on all property and rights to
property belonghng to this taxpayer for the amount of these taxes, and n o
additional penalties, lnterest, and costs that may accrue. ,= --
Name of Taxpayer TIMOTHY CLARK - 1
Residence 9 SAND PINE COURT s r.
MECHANICSBURG, PA 17050 -0000 -
IMPORTANT RELEASE INFORMATION For each assessment fisted below
unless notice of the lien is refiled by the date given in column (e), this notice shaft, _
on the day following such date, operate as a certificate of release as defined
I IRC 6325(a). ~--
Tax Period Date of Iast�for UnpaM Balance
Kind of Tax Ending Identifying Number Assessment of Assessment
a) (b ) (c ) (d) a (f)
1040 12/31/2004 XXX -XX -5346 02/22/2010 03/23/2020 362621.33
1040 12/31/2005 XXX -XX -5346 05/18/2009 06/17/2019 224191.28
1040 12/31/2006 XXX -XX -5346 02/09/2009 03/11/2019 280466.07 .
1040 12/31/2007 XXX -XX -5346 02/09/2009 03/11/2019 255765.56
1040 12/31/2008 XXX -XX -5346 07/20/2009 08/19/2019 182747.26
-NOW
-rte.
nee
Place of Filing ~�
Prothonotary
Cumberland County Total �$ 1305791.50
Carlisle, PA 17013
This notice was prepared and signed at DETROIT, MI , on this
the 31st day of March 2010
Signature Title
REVENUE OFFICER 22 -06 =14
for DENNIS P ZMUDZIN (717) 777- 9624
(MOM Certificate of officer auttwrized by law to take acknowledgment is not essential to the validity of Notice of Federal Tax Gen '° mom
Rev. Ruh. 71 - 2 C.B. aosj Form 669M(c) (Rev. 2 -2004)
Pars I - Kept By RwArding 0WIve CAT. NO 60025X ""
C
�t1
.A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAl�
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION 1 � '.
Case No. I �
Plaintiff p .4
vs.
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
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.
Respectfull ml ed:
k
(Signature o Couns 1 for Plaintiff)
1/8/2014
Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Fleas 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
Plea-so provide the following information to the hest of your knowledge:
'JARY APPLICANT
Borrower name(s):
Property Address;
City: State: Zip:
Is the property for sale? Yes El No E3 Listing date: Price:
Realtor Name: _ Realtor Phone:
Borrower Occupied? Yes No Q
Mailing Address (if different):
City: State' Zip:
Phone Numbers: Home; office:
Cell: Other;
Email:
of people in household: How long?
Mailing Address;
Gi.: State: Zip:
. ..........
Phone Numbers: Home: Office:
Cell: Other:
Email:
# ofpeople in household; How long?
First Mortgage Leader:
Type of Loan:
Loan Number: bate You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan plumber:
Total Mortgage Payments Amount: $ Included Taxes & Insurance;
Date of Last Payment:
Primary Reason for Default:
is the loan in Bankruptcy? 'Yes F1 No
ff yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ - - -- $
Retirement Funds: $ $
Investments: $
Checking:
Savings: $ $
Other: �
Automobile #1: Model: Year:
Amount awed: Value: _
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats �mc�torcycles ); Model
Year: Amount owed: Value
Montll!y Income
Name of Employers;
I.
2.
3.
Additional Income Description (not wages):
1. monWy amount:
2. monthly amount:
Borrower Pay Days: Co Borrowver Pay Days:
Monthly Exg ser. (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
lvlo a e Food
2 Ivlort a e Utilities
Car Pa eot s Condo/Nei , Fees
Auto Insurance Med. not coved
Auto fuel/repairs Other prop, payment
Install. Loan Payment Cable TV
Child Su rtlAlim, Spending Monti
Da !Child GarelTui €. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses.
Have you been working with a Housing Counseling Agency?
Yes ❑ No Q
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone.(Office): Fax:
Email:
Have you made application for :Homeowners Emergency 1Vlortgage Assistance Program
(14EMAP) assistance?
yes (] No Cj
If yes, please indicate the status of the application:
Have you had any prior negotiations with your tender or lender's loan servicing company
to resolve your delinquency?
yes E] NoO
If yes, please indicate the status of those negotiations:
Please provide the follwA ng information, if know, regarding your lender or leader's loan
servicing company:
Lender's Contact (Dame): Phone:
Servicing Company (Name):
Contact: Phone:
urrHORIZATION
rAve, , authorize the above
named to uselrefer this information to my lenderlservicer for the sole
purpose of evaluating my financial situation for possible mortgage options. Me
understand that Uwe am/are under no obligation to use the services provided by the above
named
Borrower Signature. Date
Co- Borrower Signature Date
'lease forward this document along with the .following information to lender and
lender's counsel:
Proof of income
i►
Past 2 bank statements
Proof of any expected income for the last 45 days
Y Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation .
(hardship letter)
Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
xxixtr ot x
Jody S Smith ` '� .i ' 2 f A,;,; i( ,
Chief Deputy
Richard W Stewart " t °Y
i ' ig,
Solicitor � f>m r _,�, � a _ R.
JPMorgan Chase Bank, National Association Case Number
vs.
Timothy Allen Clark(et al.) 2014-225
SHERIFF'S RETURN OF SERVICE
01/10/2014 10:30 AM- Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Annette Dente, Mother of Carla Dente-Clark, who
accepted as"Adult Person in Charge"for Carla J. Dente-Clark at 9 Sand Pine Court, Hampden
Township, Mechancisburg, PA 17050.
SHAWN GUTSHALL, DEPUTY
01/14/2014 05:34 PM- Deputy Dawn Kell, 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:
Timothy Allen Clark at 719 Westwood Drive, East Pennsboro, Enola, PA 17025.
14se.Q.
DAWN KELL, DEPUTY
SHERIFF COST: $72.25 SO ANSWERS,
January 15, 2014 RONIR ANDERSON, SHERIFF
C s
Nal 1:
F1.4:41d-
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION;et CASE and/or DOCKET No.: 14-225C1VIL
seq. c")
Plaintiff(Petitioner)
rrk
Sheriffs Sale Date:
c
TIMOTHY A.CLARK; et al.
Defendant(Respondent) r .t
AFFIDAVIT OF SERVICE
Complaint Summons LI Other:
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 THE UNITED STATES OF AMERICA the above process on the 23 day of January,2014,at 11:45 o'clock,AM,at HARRISBURG FEDERAL
BUILDING&COURTHOUSE,228 WALNUT STREET, SUITE 220 HARRISBURG,PA 17108,County of Cumberland,Commonwealth of Pennsylvania:
Manner of Service:
By handing a copy to:
An officer,partner,trustee,or registered agent of the Defendant organization who is not a plaintiff in the action*
The manager,clerk,or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a
plaintiff in the action*
An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action*
* Name: SUSAN MELENDEZ
Relationship/Title/Position:ADMINISTRATIVE ASSISTANT-AUTHORIZED TO ACCEPT.
Remarks:
Description:Approximate Age 51-55 Height 5'8 Weight 160 Race WHITE Sex FEMALE Hair BLONDE
Commonwealth/State of ea
)SS:
County of is•lc { )
Before me,the undersigned notary public,this day,personally,appeared 1t1t." to me known,who being
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.
Subscribed and sworn to before m
(Signature of Affiant) this&f day of : t y .
File Number:116880FC
Case ID#:3870606 Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. Affierbach, Notary Public
Washington Township, Barks County
My Commission Empires November 18,2017
KML Law Group, P.C.
SUITE 5000—BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106-1532s�1 f :
(215)627-1322 s 1111 ��� ll
ATTORNEY FOR PLAINTIFFS Sad
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
c/o 3415 Vision Drive
Columbus, OH 43219 CIVIL ACTION -LAW
Plaintiff
ACTION OF MORTGAGE
vs. FORECLOSURE
TIMOTHY A CLARK Term
CARLA J.DENTE-CLARK No. 14-225C1V1L
Mortgagor(s)and Record Owner(s)
9 Sand Pine Court
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE TO CORRECT PROPERTY ADDRESS
Kindly correct the caption to reflect the correct property address of 9 Sand Pine Court,
Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court, Mechanicsburg, PA 17050.
Respectfully submitted,
KML Law Group, P.C.
By: ay
KML 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
Jill P. Jenkins Pa. ID 306588
pAlyk L. Oflazian,Pa. ID 312912
Attorneys for Plaintiff
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
IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive OF Cumberland COUNTY
Columbus , OH 43219
Plaintiff CIVIL ACTION-LAW
vs.
ACTION OF MORTGAGE
TIMOTHY A CLARK FORECLOSURE
CARLA J. DENTE-CLARK Term
(Mortgagor(s) and Record Owner(s)) No. 14-225C1V1L
9 Sand Pine Court
Mechanicsburg,PA 17055
Defendant(s)
THE UNITED STATES OF AMERICA
CERTIFICATE OF SERVICE
Sarah Jim, hereby certifies that he/she did serve true and correct copies of Praecipe to
Correct Property Address and all supporting pa•ers attached hereto upon Defendant, by first
class mail, postage pre-paid, on . 0
TIMOTHY A CLARK
719 Westwood Drive
Enola, PA 17025
CARLA J. DENTE-CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court, Mechanicsburg, PA 17050
US ATTORNEY GENERAL'S OFFICE, US DOJ
950 PENNSYLVANIA AVENUE,NW
WASHINGTON, DC 20530
TIMOTHY A. CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court, Mechanicsburg, PA 17050
By:
KML Law Group,P.C. Or
Sarah Jim, Legal Assistant
sijm@kmllawgroup.com
215-825-6458 (Direct Phone)
In the Court of Common Pleas of Cumberland County
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus , OH 43219
Vs.
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055
a/Ida 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
Plaintiff
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 14- 225CIVIL
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 TIMOTHY A. CLARK and CARLA J. DENTE -CLARK and
THE UNITED STATES OF AMERICA by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 12/1/2013 to
Date of Sale per diem at $50.43
Total
(Assessment of Damages attached)
$930,590.64
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 ccu ed . nd at ast ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
AND NOW
By:
KML LA OUP, .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
Andrew F. Gornall Pa. ID 92382 y� I('�
Attorneys for Plaintiff MQ e.
C14-4`16%44
ass
Judgment is entered in favor of
NA IONAL ASSOCIATION and against CHASE BANK, g ain st TIMOTHY 1\CLAR nd CAA J. DENTE -
CLARK and THE UNITED STATES OF AMERICA by default for want of an Answer d dama asses in the sum o
$930,590.64 as per the above certification.
Prothonotary
Rule of Civil Procedure No. 236 — Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
c/o 3415 Vision Drive
Columbus , OH 43219
Plaintiff
vs.
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
THE UNT'I'ED STATES OF AMERICA
No. 14- 225CIVIL
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
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
116880 FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
. PURPOSE OF COLLECTING THE DEBT.
TO:
DATE OF THIS NOTICE: March 27, 2014
TIMOTHY A. CLARK -
CLARK, TIMOTHY A.
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050 -
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus , OH 43219 Plaintiff
vs.
TIMOTHY A CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA Defendant(s)
TO: TIMOTHY A. CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 225CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HERE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
By: . I
KMLL g G' IUP,P.C.
Mic . el McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
'Salvatore Filippello Pa. ID 313897
Jennifer Lynn Frechie Pa ID 316160
215- 627 -1322
Attorneys for Plaintiff
116880 FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
TIMOTHY A CLARK
CLARK, TIMOTHY A.
719 Westwood Drive
Enola, PA 17025
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus , OH 43219 Plaintiff
vs.
TIMOTHY A CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/Ida 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA Defendant(s)
TO: TIMOTHY A CLARK
719 Westwood Drive
Enola, PA 17025
DATE OF THIS NOTICE: March 27, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 225CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU. HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
, P.C.
ch Keever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
TSalvatore Filippello Pa. ID 313897
Jennifer Lynn Frechie Pa ID 316160
215- 627 -1322
Attorneys for Plaintiff
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
DATE OF THIS NOTICE: March 27, 2014
CARLA J. DENTE -CLARK
DENTE - CLARK, CARLA J.
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
c/o 3415 Vision Drive
Columbus , OH 43219 Plaintiff
vs.
TIMOTHY A CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine C ourt
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA Defendant(s)
TO: CARLA J. DENTE -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 225CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
By: ialt. I,t. /_A
KML LAW ``e�'Oli',P.C.
Micha •7 cK ever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Jennifer Lynn Freebie Pa ID 316160
215- 627 -1322
Attorneys for Plaintiff
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
Kim Stevens
THE UNITED STATES OF AMERICA
HARRISBURG FEDERAL BUILDING & COURTHOUSE
228 WALNUT STREET, SUITE 220
HARRISBURG, PA 17108
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus , OH 43219 Plaintiff
vs.
TIMOTHY A CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA Defendant(s)
TO: Kim Stevens
HARRISBURG FEDERAL BUILDING & COURTHOUSE
228 WALNUT STREET, SUITE 220
HARRISBURG, PA 17108
DATE OF THIS NOTICE: March 27, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 225CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A BEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400: -
By:
KMLL G'OUP,P.C.
ad McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
yk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Jennifer Lynn Freckle Pa ID 316160
215- 6274322
Attorneys for Plaintiff
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
US ATTORNEY GENERAL'S OFFICE, US DOJ
US ATTORNEY GENERAL'S OFFICE, US DOJ
950 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20530
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
c/o 3415 Vision Drive
Columbus , OH 43219 Plaintiff
vs.
TIMOTHY A CLARK
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA Defendant(s)
TO: US ATTORNEY GENERAL'S OFFICE, US DOJ
950 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20530
DATE OF THIS NOTICE: March 27, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 225CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. .
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
By:
KMLL . G'OUP,P.C.
Mic , el cKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
lyk L. Oflazian Pa. ID 312912
alvatore Filippello Pa. ID 313897
Jennifer Lynn Frechie Pa ID 316160
215 -627 -1322
Attomeys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
Plaintiff
vs.
NO. 14- 225CIVIL
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
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): TIMOTHY A. CLARK, has a last known residence of 719 Westwood
Drive, Enola, PA 17025. The following information was used to search the DMDC (check all that
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 4'04 re ating to unsworn falsification to auth.ri
Date
By: 1 l 1\..
KML LAW RI ', P.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
J, 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 : Apr-10-2014 08:12:24 AM
SCRA 3.0
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: CLARK
First Name: TIMOTHY
Middle Name: A.
Active Duty Status As Of: Apr-10-2014
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 where the individual left active duty status within 367 days preceding the Active Duty Status Date
This response reflects the individuate active duty status based on the Active Duty Status Date
■
Left Active Duty Within 367 Dais of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
,
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA _
No
NA
This response reflects whether the individual or hleher unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http: //www.defenselink.mil /faq /pis /PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: R8SA253EL0E9500
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
Plaintiff
vs.
NO. 14- 225CIVIL
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
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): CARLA J. DENTE- CLARK, has a last known residence of 9 Sand Pine
Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court, Mechanicsburg, PA 17050. The following
information was used to search the DMDC (check all that apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 4!04 r: ating to unsworn falsification to aut orities.
t
By:
KML LAW G
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
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 : Apr -10 -2014 08:16:23 AM
SCRA 3.0
Status Deport
Pursuant to Servicenembers Civil Relief Act
Last Name: DENTE -CLARK
First Name: CARLA
Middle Name: J.
Active Duty Status As Of: Apr -10 -2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA -
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA - -
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
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 /PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: R8YF953E30E9E80
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.
Plaintiff
TIMOTHY A. CLARK
CARLA J. DENTE-CLARK
(Mortgagor(s) and Record owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055
a/kla 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225CIVIL
ORDER FOR JUDGMENT
Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
, and against TIMOTHY A. CLARK and CARLA J. DENTE-CLARK/for failure to file Answer in the above action
within (20) days (or sixty (60) days if defendant is the United States o A e ica) OM t • date of service of the Complaint, in
the sum of $930,590.64.
By:
KML .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
P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
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 do 3415 Vision Drive Columbus , OH 43219 and that the
name(s) and last known address(es) of the Defendant(s) is/are TIMOTHY A. CLARK, 71 Westwood Drive Enola, PA
17025 and CARLA J. DENTE-CLARK, 9 Sand Pine Court, Mechani sb, , PA 17055. a 9 Sand Pine Court
Mechanicsburg, PA 17050;
By:
L
A
,
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
'6CJi1l P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 05/01/2012 through
11/30/2013
$866,256.04
$29,145.81
Reasonable Attorney's Fee $1,650.00
Late Charges $404.25
Escrow Advance $33,134.54
AND NOW, this ) 1 day of
14 -225 C I V 1L/ 116 8 80FC
Bv:
$930,590.64
KML LAW CR P, P.
Michael McKeever Pa. ID 56 29
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
, X014 damageSre ass ed as
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
c/o 3415 Vision Drive
Columbus , OH 43219
Plaintiff
VS.
TIMOTHY A. CLARK
CARLA J. DENTE-CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
TO THE PROTHONOTARY:
Defendant(s)
• ,•
37C)
z Q
IN THE COURT OF COMMONFPqkASLI,
4.
of Cumberland County
CIVIL ACTION – LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225CIVIL
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Amount Due
Interest from
12/1/2013 to Date of
Sale per diem at
$50.43
(Costs to be added)
By:
$930,590.64
KML LA U 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
li`–.1111 P. Jenkins Pa. ID 306588
gQ,•S -PAD—Andrew F. Gornall Pa. ID 92382
Co Attorneys for Plaintiff
S Lc-
-7b,?72
3bLi s De8
ftt 3( PE 2srvec
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
. •
Ht PROTHONOTAr,
2014 APR I I AM 11: 314
CUMBERLAND COUNTY
'MCA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
do 3415 Vision Drive
Columbus , OH 43219
Plaintiff
VS.
TIMOTHY A. CLARK
CARLA J. DENTE-CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 14-225CIVIL
THE UNEIED STATES OF AMERICA
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff, by counsel, hereby certifies that it has complied with the p ovisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By:
KML LAW ROUP,
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
C. Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
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
Plaintiff
VS.
TIMOTHY A. CLARK
CARLA J. DENTE-CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
2111 Li APR 1 1 Ari I I:
C014;TY
PENi` SYLVANIA.
IN THE COURT OF COMMON PLEAS
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129
No. 14-225CIVIL
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:
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY A. CLARK
719 Westwood Drive
Enola, PA 17025
CARLA J. DENTE-CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
2. Name and address of Defendant(s) in the judgment:
TIMOTHY A. CLARK
719 Westwood Drive
Enola, PA 17025
CARLA J. DENTE-CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
HARRISBURG FEDERAL BUILDING & COURTHOUSE
228 WALNUT STREET, SUITE 220
HARRISBURG, PA 17108
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
COMMONWEALTH OF PA
c/o Bureau of Compliance
Dept. 280948
Harrisburg, PA 17128
COMMONWEALTH OF PA
do Bureau of Compliance/Attn Sheriff Sales
POB 281230
Harrisburg, PA 17128
West Shore Country Club
100 Brentwater Road
Camp Hill, PA 17011
Susquehanna Bank
1826 Good Hope Drive
Eno la, PA 17025
Mountz Jewelers LP
3780 Trindle Road
Camp Hill, PA 17011
Susquehanna Bank
do Troy Brandon Rider , Esq/Barley Snyder LLP
50 N FIFTH ST 2ND FLOOR, POB 942
READING, PA 19603
Mountz Jewelers LP
c/o Christopher E. Rice, Esq/Martson Deardorff Williams Otto Gilroy & Faller
10 E HIGH STREET
CARLISLE, PA 17013
US TREASURY DEPARTMENT
Pittsburgh Office Room 808
1000 Liberty Avenue
Pittsburgh, PA 15222
Ally Financial Inc f/ka GMAC Inc.
555 Business Center Drive
Horsham, PA 19044
Ally Financial Inc f/ka GMAC Inc.
c/o Nauman, Smith, Shissler & Hall, L.L.P.
200 N. 3RD STREET, 18TH FL,PO BOX 840
HARRISBURG, PA 17108
COMMONWEALTH OF PA
c/o Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128
West Shore Country Club
c/o Kodak Law Offices, P.C.
407 N FRONT STREET
HARRISBURG, PA 17108
4. Name and address of the last recorded holder of every mortgage of record:
Graystone Bank
112 Market Street
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS /OCCUPANTS
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
US ATTORNEY GENERAL'S OFFICE, US DOJ
950 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20530
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 erein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authoriti s.
DATED:
L
U
� J
By: AA�
KML LAW
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
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
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.
PR
t�
1J
,`': tJ � �E(�L��:rND COU: f y
Plaintiff
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
14- 225CIVIL
Defendant(s
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 14- 225CIV1L
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: CLARK, TIMOTHY A.
TIMOTHY A. CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Your house at 9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court,
Mechanicsburg, PA 17050 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
$930,590.64 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:
14- 225CIV1L
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.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717 - 240 -6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717 - 240 -6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
14- 225C1V1L
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
116880FC.
Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344.
KML Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION 114 ThE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus , OH 43219 of Cumberland County
14-225CIVIL
2514 ilPi; 1 1 14111: 35
C /J;13ERL A
VAMP:.
Plaintiff
CIVIL ACTION - LAW
vs.
TIMOTHY A. CLARK ACTION OF MORTGAGE
CARLA J. DENTE-CLARK FORECLOSURE
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050 Docket No. 14-225CIVIL
THE UNITED STATES OF AMERICA
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE LS 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: DENTE-CLARK, CARLA J.
CARLA J. DENTE-CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Your house at 9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court,
Mechanicsburg, PA 17050 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
$930,590.64 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:
14- 225CIV1L
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.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717- 240 -6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717 - 240 -6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
14- 225C1VIL
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
116880FC.
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.
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
—The ur■ Skc kes VktiletricA
WRIT OF EXECUTION
NO 14 -225 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: $930,590.64 L.L.: 5.50
Interest FROM 12/1/2013 TO DATE OF DALE PER DIEM AT $50.43
Atty's Comm:
Atty Paid: $221.00
Plaintiff Paid:
Date: 4/11/14
(Seal)
Due Prothy: $2.25
Other Costs:
REQUESTING PARTY:
Name: JILL P. JENKINS, EQUIRE
Address:.KML LAW GROUP, P.C.
SUITE 5000 -BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 21 5- 627 -1322
Supreme Court ID No. 306588
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.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9
Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
PRQ TH,ONO j`, r .I
2014.UUG •-4 of
CUMBERLAND N A
PENN
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225C1VIL
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
Date: I VJ I t 1 By:
SAW GROUP, P.C.
701 Market Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Michael McKeever Pa. ID 56129
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
r" 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.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and
Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
THE UNITED STATES OF AMERICA
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
CERTIFICATE OF FILING
Term
No. 14-225CIVIL
Book:
Writ:
I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of
Continued Sheriff's Sale in the above upon the following parties on the date listed below:
TIMOTHY A. CLARK #70690-067
Schuylkill FCI
Interstate 81 & 901 W
Minersville, PA 17954
CARLA J. DENTE -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050 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: 7/3 /ti By: 4017,1///4/L—
KML
/ LAW GROUP, P.C.
701 Market Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Andrew Hauck
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
do 3415 Vision Drive
Columbus , OH 43219
vs.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9
Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
c11/4 411,
CUNBERL A ND COUNTY
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225CIVIL
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
Date:
By:
W GROUP, P.C.
701 Market Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Michael McKeever Pa. ID 56129
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
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.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and
Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
THE UNITED STATES OF AMERICA
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
CERTIFICATE OF FILING
Term
No. 14-225CIVIL
Book:
Writ:
I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of
Continued Sheriffs Sale in the above upon the following parties on the date listed below:
TIMOTHY A. CLARK #70690-067
Schuylkill FCI
Interstate 81 & 901 W
Minersyille, PA 17954
CARLA J. DEN lb -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055
a/k/a 9 Sand. Pine Court
Mechanicsburg, PA 17050 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: —M/
By: 4/7-7/1.----e11/1/
KML LAW GROUP, P.C.
701 Market Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332.
Andrew Hauck
1
KML LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attome for Plaintiff
JPMORGAN CHASE BANK, NATIONA
ASSOCIATION
riE PROTtiaTi Fit
.21! SEP 24 ANiJ
116880FC
CF: 01/09/2014
SD: 10/01/2014
$930,590.64
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and
Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a
9 Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
PE IN, HE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 14-225CIVIL
THE UNITED STA I ES OF AMERICA
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
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 Sheriff's 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 Sheriff's 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
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; et
seq.
Plaintiff (Petitioner)
V.
TIMOTHY A. CLARK; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 14-225CIVIL
Sheriffs Sale Date: 9/3/2014
AFFIDAVIT OF SERVICE
❑ Complaint ❑Summons El Other: NOTICE OF SALE
I, KEVEN CHASE, certify that 1 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 1
served CARLA J. DENTE -CLARK the above process on the 30 day of April, 2014, at 2:10 o'clock, PM, at 9 SAND PINE COURT, MECHANICSBURG,
PA 17055 A/K/A 9 SAND PINE COURT MECHANICSBURG, PA 17050 , County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
0 By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge
of the residence because no adult family member was found *
0 By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which
he/she resides *
El By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s') agent or to the person for the time being in
charge thereof *
* Name: ANNETTE DENTE
Relationship/Title/Position: Mother
Remarks:
Description: Approximate Age 61-65 Height 5'6 Weight 120 Race WHITE Sex FEMALE Hair BLACK
Military Status: O No ❑ Yes Branch:
Commonwealth/State of ,
County of (. elf s
) SS:
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, -deposes the following:
14C4v [L./t
1 hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct.
/A.-- -WA"'
(Signature of Affiant)
File Number:1.16880FC
Case ID #:3962754
Subscribed and sworn to be
this $ day of
to me known, who being
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. Afilerbach, Notary Public
Washington Township, Berks County
My Commission Expires November 18, 201 7
Notary Public
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY P.ENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; et
seq.
Plaintiff (Petitioner)
V.
TIMOTHY A. CLARK; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 14-225C1VIL
Sheriffs Sale Date: 9/3/2014
AFFIDAVIT OF SERVICE
❑ Complaint ❑ 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 USA the above process on the 1 day of May, 2014, at 1:35 o'clock, PM, at 228 Walnut SI,, Ste. 220, Fed. Bldg Harrisburg, PA 17108 , County of
Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
By handing a copy to:
❑ An officer, partner, trustee, or registered agent of the Defendant organization who is not a plaintiff in the action*
The manager, clerk, or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a
plaintiff in the action *
❑ An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action *
* Name: MARIAN COUGHLIN
Relationship/Title/Position: ADMINISTRATIVE ASSISTANT -AUTHORIZED TO ACCEPT.
Remarks:
Description: Approximate Age 31-35 Height 5'6 Weight 130 Race WHITE Sex. FEMALE Hair BROWN
Commonwealth/State of if
County of
13s.k�
) SS:
}
Before me, the undersigned notary public, this day, personally, appeared K t•a. 04.g.
duly sworn according to law, deposes the following:
I hereby swear or affirm that the facts sct forth in the foregoing Affidavit of Service are true and correct.
(Signature of Affiant)
File Number:116880FC
Case ID #:3962754
Subscribed and sworn t
to me known, who being
this Z day of • , 20 ear .
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAT.
Eric M. Afflerbach, Notary Public
Washington Township, Berks County
My Commission Expires November 19, 2017
Notary Public
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
| /y��
.��
SHERIFFS OFFICE OF CUMBERLAND COUNTY
of 0(
.�9�
OFFICE OF TliE SHERIFF
JPMorgan Chase Bank, National Association
vs
Timothy Alien Clark (et al)
Case Number
2014-225
SHERIFF'S RETURN OF SERVICE
06/19/2014 OO:33PM-Deputy Shawn Harrison, being duly sworn according to Iaw, states service was perforrned by
sting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, the property Iocated at 9 Sand Pine Court a/kia 9 Sand Pine Court,
Mechanicsburg, PA 17055, Cumberiand County.
0001/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014
08/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Timothy Allen Clark, but was unable to locate the
Defendant in his bailiwick. He therefore deputized the Sheriff of Schuylkill County to serve the within Real
Estate Writ, Notice and Description, in the above titled action, according to law.
09/10/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Schuylkill County upon Timothy Allen Clark, personally, at SCI Schuylkill, Interstate 81 and 901 W,
Minersville, PA 17954. So Answers: Sheriff of Schuylkill County.
SHERIFF COST: $2.309.83 SO ANSWERS,
' \
September10, 2014 RONNYR ANDERSON, SHERIFF
(c) CountySthie Sheriff, Teleosoft„ Inc.
Name and Address of Sender
:ML LAW GROUP, P.C.
iUITE 5000
'01 MARKET STREET
'HILADELPHIA, PA
9106-1532
Check type of mail or service;
❑Certified E Recorded Delivery (International)
❑ COD ❑ Registered
❑ Delivery Confirmation ❑ Return Receipt for Merchandise
❑ Express Mail 0 Signature Confirmation
❑ Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
RR
Fee
1.
'
Graystone Bank
112 Market Street
Harrisburg, PA 17101
TENANTS/ CC ANTS
2.
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand
Pine Court
. Mechanicsburg, PA 17050
US ATTORNEY GENERAL'S OFFICE, US DOJ
PENNSYLVANIA AVENUE, NW
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950
WASHINGTON, DC 20530
DOMESTIC RELATIONS OF CUMBERLAND COUNTY•
PO Box 320��,,.t
,Carlisle, PA 17013r4.
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PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child
Enforcementil
Health and Welfare Bldg. Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
5•��
•
COMMONWEALTH OF PA
c/o Bureau of Compliance
' Dept. 280948
Harrisburg, PA 17128
6-
c/o Bureau of Compliance/Atte Sheriff Sales
POB 281230
Harrisburg, PA 17128
West Shore Country Club
7 •
.100 Brentwater Road
Camp Hill, PA 17011
Susquehanna Bank
1'826 Good Hope Drive
8.
nola, PA 17025
Total Numb of Pieces j)eceivedotal
Listed by S nder �y
Number of Pi
at Post Q
s
Postmaster, Per (Na
of rec9iving employee)
i/
/I1
See Privacy Act Statement on Reverse
PS Form 387 , e ruary 2002 (Page 2 of 2)
Complete by Typewriter, Ink, or Ball Point Pen
116880FC Cumberland County Sale Date: 09/03/2014
TIMOTHY A. CLARK & CARLA J. DENTE -CLARK
Name and Address of Sender
CML LAW GROUP, P.C.
'MITE 5000
'01 MARKET STREET
'HILADELPHIA, PA
19106-1532
Check type of mail or service;
❑ Certified
❑ COD
❑ Delivery Confirmation
❑ Express Mail
❑ Insured
❑ Recorded Delivery (International)
❑ Registered
❑ Return Receipt for Merchandise
❑ Signature Confirmation
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage
Fee
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
F
Mountz Jewelers LP
A780 Trindle Road
Camp Hill, PA 17011
2.
Susquehanna Bank
c/o Troy -B a don -Rider , Esq/Barley Snyder LLP
50 N FIFTH ST 2ND FLOOR, POB 942
READING, PA 19603
SH Rr
Foe Fer;
RR
Fee
Mountz Jewelers LP
c/o Christopher E. Rice, Esq/Martson Deardorff Williams Otto
10 E HIGH STREET
CARLISLE, PA 17013
4.
6.
US TREASURY DEPARTMENT
Pittsburgh Office Room 808
1000 Liberty Avenue
Pittsburgh, PA 15222
Ally Financial Inc f/ka GMAC Inc.
555 Business Center H-Orsham, PA 19044
7.
Ally Financial Inc f/ka GMAC Inc.
c/o Nauman, Smith, Shissler & Hall, L.L.P.
200 N. 3RD STREET, 18TH FL,PO BOX 840
HARRISBURG, PA 17108
c/o Bureau of Compliance
Dept,,280946
Harrisburg, PA 17128
West Shore Country Club
c/o Kodak Law Offices, P.C.
407 N FRONT STREET
HARRISBURG, PA 17108
D
T4
Total Nyfnber of Piec
Listed b4 Sender
tal Number of Pieces
Rec ed at Post Office
PS Form 3877. Februa %e2 (Page 1 of 2)
116880FC Cumberland County
Postmaster, Per (Name of receiving employee)
Complete by Typewriter, Ink, or Bal Point Pen
Sale Date: 09/03/2014
TIMOTHY A. CLARK & CARLA J. DENTE -CLARK
See Privacy Act Statement on Reverse
Name and Address of Sender
:ML LAW GROUP, P.C.
;UITE 5000
01 MARKET STREET
,HILADELPHIA, PA
9106-1532
Check type of mail or service; , •
0 Certified El Recorded Delivery (International)
LI COD lil Registered
0 Delivery Confirmation 0 Return Receipt for Merchandise
0 Express Mail 0 Signature Confirmation
(11 Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD'UR
Fee
Fee
1.
ALLY FINANCIAL INCr....zir.......
2740 ARTHUR STREET"
•
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U.S. POSTAGEO
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...............
ZIP 19106 $ 001.300
111
JUL. 31.
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Total Number of Pieces
Listed by Sender
Total Number of Pieces
, R,ed at Post Office
Postmaster, Per (Na o c ing employee)
See Privacy Act Statement on Reverse
PS Form 3877, Feb (Page 1 of 2)
omplete by Typewriter, Ink, or Ball Point Pen
116880FC Cumberland County Sale Date: 09/03/2014
TIMOTHY A. CLARK & CARLA J. DENTE -CLARK
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
Plaintiff
vs.
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
Mortgagor(s) and Record Owner(s)
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9
Sand Pine Court
Mechanicsburg, PA 17050
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 14-225C1VIL
SUPPLEMENTAL 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:
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY A. CLARK #70690-067
Schuylkill FCI
Interstate 81 & 901 W
Minersville, PA 17954
CARLA J. DENTE -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
2. Name and address of Defendant(s) in the judgment:
TIMOTHY A. CLARK #70690-067
Schuylkill FCI
Interstate 81 & 901 W
Minersville, PA 17954
CARLA J. DENTE -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
THE UNITED STATES OF AMERICA
HARRISBURG FEDERAL BUILDING & COURTHOUSE
228 WALNUT STREET, SUITE 220
HARRISBURG, PA 17108
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
COMMONWEALTH OF PA
c/o Bureau of Compliance
Dept. 280948
Harrisburg, PA 17128
COMMONWEALTH OF PA
c/o Bureau of Compliance/Attn Sheriff Sales
POB 281230
Harrisburg, PA 17128
West Shore Country Club
100 Brentwater Road
Camp Hill, PA 17011
Susquehanna Bank
1826 Good Hope Drive
Enola, PA 17025
Mountz Jewelers LP
3780 Trindle Road
Camp Hill, PA 17011
Susquehanna Bank
c/o Troy Brandon Rider , Esq/Barley Snyder LLP
50 N FIFTH ST 2ND FLOOR, POB 942
READING, PA 19603
Mountz Jewelers LP
c/o Christopher E. Rice, Esq/Martson Deardorff Williams Otto Gilroy & Faller
10 E HIGH STREET
CARLISLE, PA 17013
US TREASURY DEPARTMENT
Pittsburgh Office Room 808
1000 Liberty Avenue
Pittsburgh, PA 15222
Ally Financial Inc f/ka GMAC Inc.
555 Business Center Drive
Horsham, PA 19044
Ally Financial Inc f/ka GMAC Inc.
c/o Nauman, Smith, Shissler & Hall, L.L.P.
200 N. 3RD STREET, 18TH FL,PO BOX 840
HARRISBURG, PA 17108
COMMONWEALTH OF PA
c/o Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128
West Shore Country Club
c/o Kodak Law Offices, P.C.
407 N FRONT STREET
HARRISBURG, PA 17108
ALLY FINANCIAL INC
2740 ARTHUR STREET
ROSEVILLE, MN 55113
4. Name and address of the last recorded holder of every mortgage of record:
Graystone Bank
112 Market Street
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale.
TENANTS/OCCUPANTS
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
US ATTORNEY GENERAL'S OFFICE, US DOJ
950 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20530
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: September 22, 2014
KML Law Group, P.C.
BY: Andrew Hauck
Legal Assistant
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 IN THE COURT OF COMMON PLEAS
ASSOCIATION
of Cumberland County
c/o 3415 Vision Drive
Columbus,OH 43219
Plaintiff CIVIL ACTION-LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
TIMOTHY A.CLARK#70690-067
CARLA J.DENTE-CLARK
Mortgagor(s)and Record Owner(s) No. 14-225CWIL
9 Sand Pine Court,Mechanicsburg,PA 17055 a/k/a 9
Sand Pine Court Book:
Mechanicsburg,PA 17050 Writ:
Defendant(s)
NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE
The Sheriff s Sale scheduled for October 01,2014 at 10:00 AM in the above matter has been continued
until November 05,2014 at 10:00 M
Date: O IO By: ti
W GROUP,P.C.
701 Market Street,Suite 5000
Philadelphia,PA 19106
(215)825-6332
Michael McKeever Pa.ID 56129
David Fein Pa. ID 82628
Jill P.Jenkins Pa.ID 306588
Alyk L.Oflazian Pa.ID 312912
Salvatore Filippello Pa.ID 313897
=/lennifer Lynn Frechie Pa.ID 316160
Attorneys for Plaintiff
a
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 IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive of Cumberland County
Columbus,OH 43219
Plaintiff CIVIL ACTION—LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
TIMOTHY A. CLARK 470690-067
CARLA J.DENTE-CLARK Term
Mortgagor(s)and No. 14-225CIVIL
Record Owner(s)
9 Sand Pine Court,Mechanicsburg,PA 17055 a/k/a 9 Book:
Sand Pine Court Writ:
Mechanicsburg,PA 17050
Defendant(s)
THE UNITED STATES OF AMERICA
CERTIFICATE OF FILING
I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of
Continued Sheriff's Sale in the above upon the following parties on the date listed below:
TIMOTHY A.CLARK#70690-067
Schuylkill FCI
Interstate 81&901 W
Minersville,PA 17954
CARLA J.DENTE-CLARK
9 Sand Pine Court,Mechanicsburg,PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg,PA 17050 defendant(s)
SHERIFF OF CUMBERLAND COUNTY
Sheriff s 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:/ //� f� By:
/// KML LAW GROUP,P.C.
701 Market Street, Suite 5000
Philadelphia,PA 19106
(215)825-6332
Veronica Cosine
c. -
r
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE n O THONG TAR)."
2014 NOV 26 PPS 2: 4 7
CUMBERLAND CII IN'TY
PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
c/o 3415 Vision Drive
Columbus ,OH 43219
vs.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand
Pine Court
Mechanicsburg, PA 17050
Defendant(s)
THE UNITED STATES OF AMERICA
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225CIVIL
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF
UNDER Pa.R.C.P. 2352
TO THE PROTHONOTARY:
Kindly file of record the Praecipe of NRZ PASS-THROUGH TRUST IV, U.S. BANK
NATIONAL ASSOCIATION AS TRUSTEE for Voluntary Substitution under Pa.R.C.P. 2352 due to
Assignment of Mortgage and attached Statement of Material Facts in Support of Voluntary Substitution,
Verification, Certification of Service. The address for the new Plaintiff is 700 Kansas Lane, MC 8000,
Monore, LA 71203.
. Bv:
L LAW GROUP, P.C.
MiLfiael 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
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
49.50 PO !LFr
'1803t1
pp31 41Qo7
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon 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.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand
Pine Court
Mechanicsburg, PA 17050
Defendant(s)
THE UNITED STATES OF AMERICA
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-225CIVIL
STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER
Pa.R.C.P. 2352
NRZ PASS-THROUGH TRUST IV, U.S. BANK NATIONAL ASSOCIATION AS
TRUSTEE, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above -captioned matter and in
support thereof represents as follows:
1. The above -captioned Action of Mortgage Foreclosure relates to a property located at 9 Sand Pine
Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court Mechanicsburg, PA 17050 ("Property").
2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book 1762, Page 3908
in the Office of the Recorder of Deeds for Cumberland County.
3. The original Plaintiff in this action is JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
4. NRZ PASS-THROUGH TRUST IV, U.S. BANK NATIONAL ASSOCIATION AS
TRUSTEE is the successor in interest to the Plaintiff by an assignment of mortgage recorded in land records of
Cumberland County on July 29, 2014 in Instrument # 201416544 and is hereby voluntarily substituted as Plaintiff in
the above -captioned matter.
Respectfully submitted,
L 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
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
KML LAW GROUP, P.C.
SUITE 5000 — BNY MELLON 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.
Plaintiff
TIMOTHY A. CLARK #70690-067
CARLA J. DENTE -CLARK
(Mortgagor(s) and Record Owner(s))
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9
Sand Pine Court
Mechanicsburg, PA 17050
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Defendant(s)
THE UNITED STATES OF AMERICA
CERTIFICATE OF SERVICE
Term
No. 14-225CIVIL
Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe
for Voluntary Substitution and al supporting papers attached hereto upon Defendant, by first
class mail, postage pre -paid, on h l i $v} 14 .
TIMOTHY A. CLARK #70690-067
Schuylkill FCI
Interstate 81 & 901 W
Minersville, PA 17954
CARLA J. DENTE -CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
TIMOTHY A. CLARK
719 Westwood Drive
Enola, PA 17025
TIMOTHY A. CLARK
9 Sand Pine Court, Mechanicsburg, PA 17055 a/k/a 9 Sand Pine Court
Mechanicsburg, PA 17050
TIMOTHY A. CLARK
2250 Millennium Way
Enola, PA 17025
THE UNITED STATES OF AMERICA
HARRISBURG FEDERAL BUILDING & COURTHOUSE
228 WALNUT STREET, SUITE 220
HARRISBURG, PA 17108
By: W
KML Law Group, P.C.
Doris Guzman, Legal Assistant
Dguzman@kmllawgroup.com
215-825-6402 (Direct Phone)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FI'_ .! I_CF F,Cr..
THc- r'ROT(-s'MO lAW,'
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFFICE OF THE SHERIFF
21',DEC 31 PM 2:39
CUMBERLAND COUNTY
PENNSYLVANIA
JPMorgan Chase Bank, National Association
vs.
Timothy Allen Clark (et al.)
Case Number
2014-225
SHERIFF'S RETURN OF SERVICE
06/19/2014 08:33 PM - Deputy Shawn Harrison, 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 9 Sand Pine Court a/k/a 9 Sand Pine Court,
Mechanicsburg, PA 17055, Cumberland County.
08/01/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014
08/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Timothy Allen Clark, but was unable to locate the
Defendant in his bailiwick. He therefore deputized the Sheriff of Schuylkill County to serve the within Real
Estate Writ, Notice and Description, in the above titled action, according to law.
09/10/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Schuylkill County upon Timothy Allen Clark, personally, at SCI Schuylkill, Interstate 81 and 901 W,
Minersville, PA 17954. So Answers: Sheriff of Schuylkill County.'
09/30/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 11/5/2014
11/05/2014 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 17013, on November 05, 2014 at
10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Michael McKeever, on behalf of the xxxxx.
xxxxx, being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $1,993.93 SO ANSWERS,
November 17, 2014
(c) CouritySute Sheriff, Teleosctt, Inc.
RONNY R ANDERSON, SHERIFF
a- as, pd . Co'
Q 1,12
04 3/5" /2
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.
TIMOTHY A. CLARK
CARLA J. DENTE -CLARK
—1'ke Uric SiakeS ` Citekic&
WRIT OF EXECUTION
NO 14-225 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: $930,590.64 L.L.: $.50
Interest FROM 12/1/2013 TO DATE OF DALE PER DIEM AT $50.43
Atty's Comm: Due Prothy: $2.25
Atty Paid: $221.00 Other Costs:
Plaintiff Paid:
Date: 4/11/14
REQUESTING PARTY:
Name: JILL P. JENKINS, EQUIRE
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. 306588
TRUE COPY FROM RECORD
In Testirnony whereof, i here unto set my hand
and the seal of said Court at Carlisle. Pa.(�
This (( day of {(t 1 .20 (Li
`.�W� Prothonotary
LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14
Writ No. 2014-225 Civil
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION
vs.
TIMOTHY ALLEN CLARK
Carla J. Dente -Clark
Atty.: Michael McKeever
All That Certain tract of land situ-
ate in Hampden Township, Cumber-
land County, Pennsylvania, being Lot
No. 25 as shown on the Plan entitled
Pinehurst Final Subdivision Plan
Phase V, dated January 19, 1998 and
recorded in Cumberland County Plan
Book 76, Page 112, more particularly
bounded and described as follows:
BEGINNING at an iron pin, being
an easterly corner of Lot No. 24 and
lying in a southerly right-of-way line
of Sand Pine Court (50 -foot right-of-
way); thence along said right-of-way
line, South 57 degrees 42 minutes 51
seconds East, 89.41 feet to an iron
pin, being a southerly corner of said
right-of-way and being a westerly
corner of Sand Pine Court cul-de-sac
(60 foot right-of-way); thence along
said right-of-way line, along a curve
to the right, having a chord bearing
of South 30 degrees 43 minutes 48
seconds East, a chord distance of
22.69 feet, a radius of 25.00 feet, and
an arc length of 23.55 feet to an iron
pin; thence continuing along said
right-of-way line along a curve to the
left, having a chord bearing of South
40 degrees 46 minutes 48 seconds
East, a chord distance of 72.27 feet,
a radius of 60.00 feet, arid an arc
length of 77.56 feet to an iron pin,
lying in a southerly line of said right-
of-way, and being a westerly corner
of Lot No. 26; thence along Lot No.
26, South 14 degrees 02 minutes 09
seconds West, 375.71 feet to an iron
pin, being a westerly corner of said lot
and lying in a northerly line of lands
now or formerly of Susquehanna
Enterprises, Inc.; thence along said
lands, North 77 degrees 11 minutes
29
41 seconds West, 160.00 feet to an
iron pin, lying in a northerly line of
said lands and being a southerly
corner of Lot No. 24; thence along
Lot No. 24, North 14 degrees 02
minutes 09 seconds West, 464.90
feet to an iron pin, being the place of
BEGINNING.
CONTAINING 1.560 acres.
Lot No. 25 is subject to a 10 -foot
wide utility easement along its street
frontage, a 30 -foot sanitary sewer
easement which traverses said lot, a
40 -foot drainage easement centered
on a stream, 10 feet of a 35 -foot wide
sanitary sewer and storm sewer ease-
ment along its easterly boundary,
and a wetland area being bounded
and described as follows:
BEGINNING at a concrete monu-
ment, lying in an easterly line of
Lot No. 24 and lying in a westerly
line of Lot No. 25; thence along said
line, North 14 degrees 02 minute 09
seconds East, 40.83 feet to a con-
crete monument; thence traversing
through Lot No. 25, South 65 degrees
34 minutes 29 seconds East, 110.28
feet to a concrete monument; thence
continuing through said lot, South 64
degrees 14 minutes 40 seconds East,
52.59 feet to concrete monument,
lying in an easterly line of said lot
and lying in a westerly line of Lot No.
26; thence along said line, South 14
degrees 02 minutes 09 seconds West,
66.11 feet to a concrete monument;
thence traversing through Lot No.
25, North 45 degrees 19 minutes 12
seconds West, 53.79 feet to a con-
crete monument; thence continuing
through said lot, North 60 degrees
28 minutes 43 seconds West, 95.38
feet to a concrete monument; thence
continuing through said lot, North 68
degrees 11 minutes 55 seconds West,
21.97 feet to a concrete monument,
being the place of BEGINNING.
UNDER AND SUBJECT, NEVER-
THELESS, to Declaration of Pine-
hurst, Phase V, a Planned Communi-
ty, dated April 29, 1998 and recorded
LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14
May 1, 1998 in Cumberland County
Miscellaneous Book 575, Page 376.
UNDER AND SUBJECT, NEVER-
THELESS, to Declaration of Con-
servation Easement dated April 29,
1998 and recorded May 1, 1998 in
Cumberland County Miscellaneous
Book 575, Page 407.
IMPROVEMENTS consist of a
residential dwelling.
MUNICIPALITY Hampden Town-
ship.
BEING PREMISES: 9 Sand Pine
Court, Mechanicsburg, PA 17055
a/k/a 9 Sand Pine Court, Mechan-
icsburg, PA 17050.
SOLD as the property of Timothy
A. Clark and Clara J. Dente- Clark,
husband and wife.
TAX PARCEL # 10-14-0842-167.
BEING the same premises which
Fred A. Tiday and Darlene J. Tiday,
husband and wife by deed dated
6/21/2002 and recorded 6/24/2002
in Cumberland County in Deed Book
Volume 252 at Page 1597 granted
and conveyed unto Timothy A. Clark
and Clara J. Dente -Clark, husband
and wife.
30
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.
isa Marie Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
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
-the Patriot -News Co.
11900 Patriot Drive
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
he atriotXews
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
it d for_said_County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
14-225 Civil Term
JP ORGAN CHASE BAN ',
N TIONAL ASSOCIATIO I
vs.
TIMOTHY ALLEN CLARK
Carla J. Dente -Clark
Atty: Michael McKeever
All That Certain tract of land situate
in Hampden Township, Cumberland
County, Pennsylvania, being Lot
No. 25 as shown on the Plan entitled
Pinehurst Final Subdivision Plan
Phase V, dated January 19, 1998 and
recorded in Cumberland County Plan
Book 76, Page 112, more particularly
bounded and described as follows:
BEGINNING at an iron pin, being
an easterly corner of Lot No. 24 and
lying in a southerly right-of-way line
of Sand Pine Court (50 -foot right-of-
way); thence along said right-of-way
line. South 57 degrees 42 minutes 51.
seconds East, 89.41 feet to an iron pin,
being a southerly corner of said right-
of-way and being a westerly corner
of Sand Pine Court cul-de-sac (60
foot right-of-way); thence along said
right-of-way line, along a curve to the
right, having a chord beasinanfSouth
30 degrees 43 minu e1 r1 seconds
East, a chord distance of 22.69 feet, a
e
r
1
This ad ran on the date(s) shown below:
07/13/14
07/20/14
07/27/14
Sworn to , ubscribed before me this 20 day of August, 2014 A.D.
ot.cy)Public
COMMONWEALTH OF PENNSYLVANIA
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 NRZ REO IV Corp is the grantee the same having been sold to said grantee on
the 5th day of November A.D., 2014, under and by virtue of a writ Execution issued on the l l th day of
April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2014 Number
225, at the suit of JP Morgan Chase Bank N A against Timothy A Clark & Carla J Dente -Clark is duly
recorded as Instrument Number 201430362.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
J.
, A.D. o? Opti
21"tog
day of
corder of Deeds
Recorer of De'. s. Cumberland County, Carlisle, PA
My Commission Expires the First Monday of Jan, 2018