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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 ^'^48 t ` ..... ak,Support �(�` • t•• - `rti Ja1OSZA'vP �.c, S0 �p�� ‘...39q C'Q'Ao,f% Q� 3. s S� 950 WASHINGTON, DC 20530 DOMESTIC RELATIONS OF CUMBERLAND COUNTY• PO Box 320��,,.t ,Carlisle, PA 17013r4. h kr ...\‘.... yf 7 s�0 0 eo N S.s 4. t I' 19 c:5‘ )jz ay ' ' 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" • '4 • ...;. 414 51.- , y : 02 • 0001391829 U.S. POSTAGEO PITNEY BOWES riallivalsumor 2014 ............... ZIP 19106 $ 001.300 111 JUL. 31. 2. VIL , MN 11 3. 4. USP ' ."-• 5. .' • i; K... (4, - ' ., • • , ' ' - .1.. . 6. 7. • 8. 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