Loading...
HomeMy WebLinkAbout14-0226 r Supreme Court of Pennsylvania Courof za rnaria><z Pleas C11 "l1<;C © [`Q1, Sl;�eet For Prothonotary C u ' m be rland j.` ` County Doi Qt v °: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the din and service of leadin s or other papers as re quired b law or rules o court. Commencement of Action: ® Complaint 13 Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: C JPMORGAN CHASE BANK, NATIONAL DUSTIN L SHERMAN ASSOCIATION T I O Are money Damages requested ?: ❑ Yes No Dollar Amount Requested within arbitration limits (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes NO Is this an MDJ Appeal? ❑ Yes NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation 5 ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other � mass tort) ❑Employment dispute: C ❑ Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute: Other T ❑ Other: 0 MASS TORT ❑ Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Tonic Waste ❑ Other 13 Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P_ 205.5 Updated 1/1/2011 I£ML LAW GROUP, P.C. �, SUITE 5000 -BNY MELLON INDEPENDENCE CENTER, j ��1 -, D r FIC 701 MARKET STREET i }I P2 V { N0 TA R y PHILADELPHIA, PA 19106 (866) 413 -2311 20 h JAN — 9 AM N: q 2 2 JPMORGAN CHASE BANK, NATIONAL CUMBERLANG ! OW01 THE COURT OF COMMON PLEAS ASSOCIATION PENNSYLVANIA 3415 Vision Drive OF Cumberland COUNTY Columbus, OH,43219 Plaintiff CIVIL ACTION - LAW VS. ACTION OF MORTGAGE FORECLOSURE DUSTIN L SHERMAN Mortgagor(s) and Record Owner(s) CM AMON: M ORTC AUI 91 Cold Springs Road gp Q$j, " Carlisle, PA 17015 Defendant(s) � � _ O� ts) 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) dial de piazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner . de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O c� SI NO TIENE EL SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME V POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA� ��•x AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Q F'01 CiL* 7559! � @�s 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.12hfa.org/consumers/homeowners/real.aspx 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(ic 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 127530FC. Para informacion en espanol puede communicarse con Loretta a1215- 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, 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are DUSTIN L SHERMAN, 91 Cold Springs Road, Carlisle, PA 17015, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 27, 2012 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR NFM, INC DB /A NFM CONSULTANTS, INC.,, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on April 05, 2012 as Instrument# 201209916. The mortgage has been assigned to: JPMORGAN CHASE BANK, NA by assignment of Mortgage recorded on November 05, 2013 as Instrument# 201335826. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for August 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of December 5, 2013: PrincipalBalance ...................................... ............................... .....................$99, Interest from 07/01/2013 through 11/30/2013 ........................ ......................$1,341.65 AccruedLate Charges ................................. ............................... ........................$153. EscrowAdvance ......................................... ............................... ........................$63 SuspenseBalance .............................................................. ............................... ($700.00) Reasonable Attorney's Fee $1,650.00 .............................. ............................... $102,155.05 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $102,155.05, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: -- KML LAW 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 1. Goldman Pa. ID 205047 — g ill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Pennsylvania Verification Shanteria D. Davis , hereby states that he / she is Vice President of JPMorgan Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Shanteria D. Davis Vice President Date: 1;?. ?- 13 JPMor2an Chase Bank, N.A Borrower:JV' �,� p,! r'` � ��✓�`""� Property Address: County: Last Four of Loan Number: (Q Ej(hibitA Inst. # 201209916 - Page 10 Of 11 CKRTIFIED PROPERTY IDENTIFICATION NUMBERS 08 -32- 2326 -022 - DICKINSON TP CCGIS REGISTRY 04/05/2012 BY Gy i i Exhibit "A ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BECaN1 ING at a past on the eastern side of the Cold Springs Road at the corner of lands previously conveyed to M. Arthur Naylor and Grace Lee Naylor, his wife; thence along said Cold Springs Road, North 23 degrees East 140 feet to a point 4t line of lands previously conveyed to Charles Lillie; thence by said latter lands, South 72 degrees East 250 feet to a point; thence by the same, North 23 degrees East 10 feet to a point; thence by the same, south 72 degrees East 100 feet to a point at Otte Of lands now or formerly of John P. McCoy; thence by the same, south 23 degrees West 130 feet to a point; thence by lands of WL Arthur Naylor, et ua, North 72 degrees Nest 350 feet #o a post on the eastern side of the Cold Springs Road, the place of SEGLNNING * *FOR INFORMATIONAL PURPOSES ONLY** The improvements thereon being known as No. 91 Cold Springs Road, Carlisle, PA 17015. Being the same property, which by Deed dated IV26/07 and recorded 12/11/07 in Instrument No. - 200745968, in Office of the Recorder of Deeds of Cumberland County,'Pennsylvania, was granted and conveyed by Deutsche Bank National Trust Company, as Trustee for Vendee Mortgage Trust 2003 -1, without recourse, except as provided a Pooling and Servicing Agreement dated February 1, 2003 by Countrywide Home Leans, Inc. its Attorney in Fact by Power of Attorney recorded 8/25105 BK 720 PG 1165 unto Dustin L Sherman. PARCEL ID NO: 08-32- 2326-022 i. i i i i E -�C h ibit �B *Exhibit has been redacted to remove all personally identifiable information or non public information Chase (FL5 -7734) ; P.O. Box 44090 C HASE go Jacksonville, FL 32231 -4090 IIIIIIIIl,l llllll l,IlII�IIIII September 30, 2013 00003766 HDLG ZB 27613 -BR640 DUSTINL SHERMAN 91-COLD SPRINGS RD CARLISLE, PA 17015 Acceleration Warning (Notice of Intent to Foreclose) Account: =6394 (the "Loan ") Property Address: 91 COLD SPRINGS RD CARLISLE, PA 17015 (the "Property") Dear DUSTINL SHERMAN: 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: L You are in default because you have failed to pay the required monthly installments commencing with the payment due August 1, 2013. 2. As of September 30, 2013, 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 $1,995.34 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. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848 -9380. Total Monthly Payments $018.60 Late Fees $76.74 NSF Fees- $0.00 Other Fees* $0.00 Advances* $0.00 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 of November 2, 2013 set forth in Paragraph 4 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 number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 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. 6. If you fail to cure the default on or before November 2, 2013, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. 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. 7 If putted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. 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 related to any foreclosure action we initiate. 8. 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 payment. 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. 9. 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. 10. 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 anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. 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) 5694287 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 - 9954673. 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. - BR840 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. Federal Trade Commission °'` 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 AAA HOPENQW Support .& Guidance:For Homeowners EVF/AVVN MLSM MAILING HOME AFFORDABLE.GOV hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information _ I Inst. # 201335826 - Page CERTIFIED PROPERTY IDENTIFICATION NUMBERS 08 -32- 2326 - 022 - DICKINSON TP CCGIS REGISTRY 11/05 /2013 BY TB Prepafed / Return To E.Lance/NTC, 2100 AIL 19 North, Palm Harbor, FL 34683 (800)346 -9152 Loan #: -6394 i Tax C ode/PIN/UPI # 08 -32 -2326 -022 1 111111 11111 11111 IN 1111111111113 1111111111 1111 1111 IN I ASSIGNMENT OF MORTGAGE Contact JPMORGAN CHASE BANK, N.A. for this instrument 780 Kansas Lane, Suite A, Monroe, LA 71203, telephone # (866) 756 -8747, which is responsible for receiving payments. FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NY INC. D/B /A NFM CONSULTANTS, INC., ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PPO BOX 2026, FLINT, MI, 48501, (ASSIGNOR), (MFRS Address: 1901 E Voorhees Street, Suite C, Danville, II.. 61834) by these presents does convey, grant, assign, transfer and set over the described Mortgage therein together with all interest secured thereby, all Lens, and any rights due or to become due thereon to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE). Said Mortgage is dated 03/27/2012, in the amount of $105,572.00, made by DUSTIN L. SHERMAN to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR NFM, INC DIB /A NFM CONSULTANTS, INC., recorded on 04/05/2012, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book rn/a, Page n/a, and/or Document # 201209916, . Property is cqmjrnonly known as: 91 COLD SPRINGS ROAD TWP. OF DICKINSON, CARLISLE, PA 17015. Dated on _ / /YYYY) MORTGA E ELE (�' IRON IC RONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NFM, INC. D/B /A NFM CONSULT , INC., ITS SUCCESSORS AND ASSIGNS By IAJ ASST. SECRETARY PAGE 1 JPCAS 22112786 -- CHASE C15682814 N1 MIN 100259100011763004 MFRS PHONE 1- 888 - 679 -6377 T3013102410 (C -21 FRMPA I 111111111 lilt 11111311111111 IN Ill 1111 111 Hill 1111111111111111111111111111111111111111111111111 1111111111111111111111111 •1)0004063338' 4 Inst. # 201335826 - Page 2 of 3 Loan II: 394 (IlfIN 11111 VIII VIII Illll 11111 11111 lllfl VIII 11111 1111 1111 STATE QF LQ�JIMA PARISH OF OUACHITA �l,� ��/� On �U 1 'I 1 P2013 (M]vVDD/YYYY), before me appeared r �� L N/1 MR416 l�C to me personally known, who did say that he/she/they is/are the ASST. SECRETARY of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NFM, INC. DB /A NFM CONSULTANTS, INC., ITS SUCCESSORS AND ASSIGNS and that the instrument was signed on behalf of the corporation (or association), by authority from its board of directors, and that he/shetthey acknowledged the instrument to be the free act and deed of the. corporation (or association). Y. K. WILSON OUACHITA PARISH. LOUISIANA 77 y W -- 7s�n u N0 ARY Dtl µ 084399 N Notary Public - State of LOUISIANA Commission expires: Upon My Death Assignment of Mortgage from: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NFM, INC. DB /A NFM CONSULTANTS, INC, ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PO BOX 2026, FLINT, MI, 48501, (ASSIGNOR), (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) to: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE) Mortgagor_ DUSTIN L. SHERMAN 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: 91 COLD SPRINGS ROAD TWP. OF DICKINSON CARLISLE, PA 17015 CUMBERLAND (Borough or Townshipp, if stated), Commonwealth of Pennsylvania. Bein cularfy ri i Mortgage. hereby certify that the below information and address for the assignee are correct JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MO E, LA 203 (866)756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE) w s By: r W, _� ASST. SECRETARY PAGE *22112786" JPCAS 22112786 —CHASE CJ5682814 N 1 MIN 100259100011763004 MERS PHONE 1- 888 - 679 -6377 73013102410 [C -2J FRMPAI 1111111111 IN 111111111111111111111111111111111 111111111111111111111111111111111111111 Pill III 1111111111111111111 •D0004063338• i Inst. # 201335826 - Page 3 of 3 I ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY. 1 COURTHOUSE SQUARE " A. r A. CARLISLE, PA 17013 717 - 240 -6370 Instrument Number - 201335826 Recorded On 11/5/2013 At 8:15:02 AM * Total Pages - 3 • Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 150700 User ID - SW • Mortgagor - SHERMAN, DUSTIN L • Mortgagee - JPMORGAN CHASE BANK N A * Customer - SEUPLIFILE LC &RECORDING * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.00 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $56.00 I i i I Certify this to be recorded in Cumberland County PA RECORDER OF DEEDS Trio i * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NAT_ IONAL ASSOCIATION Plaintiff Case No. 1 I u ' ; VS. ► 6 9 �� � �� DUSTIN L SHERMAN Defendant(s) .-at NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully u itt (Signature of laintiff) 1/8/2014 Date i Cumberland County Residential :Mortgage Foreclosure Diversion Program Financial Worksheet Date _ Cumberland County Court of Common Pleas Docket BORROWER REQUEST FOR HARDS141P ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine passible options while working with your Please provide the fallowing information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes [D No Listing date; Price: $ Realtor Name: _ Realtor Phone: Borrower Occupied? Yes L No Mailing Address (if different): City: State; Zip: Phone Numbers: Home: _ Office: Cell: Other: Email: of people in household: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: C}ffice: Cell: Other: - Email; of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: . Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance; Date of Last Payment: Primary Reason for Default: 1s the loan in Bankruptcy? Yes NoEl If yes, provide names, location of court, ease number & attorney: Assets A rnotint Owed Value: Home: $ $ Other Real Estate. $ - -- .Retirement Funds: $ �; Investments. $ Checking: $ $ Savings: $ $ Other: $ $ Automobile fl: : Model: Year: Amount owed: Value- Automobile #2 Model: - � `Fear: Amount owed: Value: Other transportation (automobiles, boats Motorcycles); Model- _ year: Amount owed: Value Monthly Income Name of Employers: 1 2. 3. .Additional Income. Description (not wages ): 1 • monthly amount: 2. monthly amount: Borrower Pay days: - -.__ _ _ Co Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) .......... . EXPENSE AMOUNT EXPENSE AMOUNT Mo a e Food 2 Mori a e Utilities Car Pa ens Condo/Neigh. Fees _ Auto Insurance Med. riot coveL Auto fuel/repairs Qther prop. payment Install -Loan Payment Cable TV Child Su rt/Alirrr. S pending Mone Da /Child CarelTuit. {)thee Ex eases Amount Available for Monthly Mortgage Payments Based on - Income & Expenses: Have you been working with a lousing Counseling Agency? Yes El No El If yes, please provide the following information: Counseling Agency: Counselor: Phone.(Offce): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [ No If ;yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes No E] If yes, please indicate the status of these negotiations: Please provide the follo%ring information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Name); Phone: Servicing Company (Name): _ Contact:: Phone: MaHORIZA authorize the above named to uselrefer this information to my lender /servicer for the sole Purpose of evaluating my financial situation for possible mortgage options. I/We. understand that I/we am/are under no obligation to use the services provided by the above named $orrorver Signature Date Co- Borrower Signature Date Please forward this document along with the fallowing informations to lender and lender's counsel: Proof of income V fast 2 bank statements Proof of any expected income for the last 45 days Copp of a current utility bill Y 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 Jody S Smith ry Chief Deputy Richard W Stewart Solicitor" Y i_VA N1 JPMorgan Chase Bank, National Association Case Number vs. Dustin L Sherman 2014-226 SHERIFF'S RETURN OF SERVICE 01/13/2014 09:35 AM - Corporal William Cline 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: Dustin L Sherman at Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. TN(CftAM CLINE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, 4 January 13, 2014 RONIV R ANDERSON, SHERIFF KAM LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 _ (.1 i HE PROTHONO JUS -9 LTh 9;55 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. DUSTIN L SHERMAN (Mortgagor(s) and Record owner(s)) 91 Cold Springs Road Carlisle, PA 17015 Defendant(s) utiMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 14-226 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER Mic ael McKeever Pa. ID 56129 Ja E. Kivitz Pa. ID 26769 Li a Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 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 DUSTIN L SHERMAN 91 Cold Springs Road Carlisle, PA 17015