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HomeMy WebLinkAbout14-155341. S E C T I 0 N A S E C T I 0 N Court of Common Pleas Civil Cover Sheet Cumberland County The information collected on this form is used solely for court administration purposes. This form does not For Prothonotary Use Only: Lead Plaintiff's Name: JPMorgan Chase Bank, National Association Docket No: ) supplement or replace the fihin and service of leadin s or other papers as required by law or rules of court. Commencement of Action: „ Eg Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking Lead Plaintiff's Name: JPMorgan Chase Bank, National Association Lead Defendant's Name: Krista L. Leach Are money damages requested?: 0 Dollar Amount Requested: (Check one) El within arbitration limits Yes 4 No outside arbitration limits Is this a Class Action Suit? 0 Yes Is this an MDJ Appeal? 0 Yes Ej No 4 No Name of Plaintiff/Appellant's Attorney: El Check here if you Christopher A. DeNardo, Esquire [Pro Se] Litigant) have no attorney (are a Self-Represented Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your type of claim, check the one that PRIMARY CASE. If you are making more than one you consider most important. TORT (do not include Mass Tort) 0 Intentional 0 Malicious Prosecution 0 Motor Vehicle El Nuisance 0 Premises Liability 0 Product Liability (does not include mass tort) 0 Slander/Libel/Defamation 0 Other: CONTRACT (do not include Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card 0 Debt Collection: Other CIVIL APPEALS Administrative Agencies 0 Board of Assessment 0 Board of Elections 0 Dept. of Transportation 0 Statutory Appeal: Other 0 Employment Dispute: Discrimination El Employment Dispute: Other El Zoning Board 0 Other: 0 Other: MASS TORT 0 Asbestos El Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant 0 Toxic Waste 0 Other: REAL PROPERTY 0 Ejectment 0 Eminent Domain/Condemnation 0 Ground Rent 0 Landlord/Tenant Dispute Z Mortgage Foreclosure: Residential 0 Mortgage Foreclosure: Commercial 0 Partition 0 Quiet Title 0 Other: MISCELLANEOUS 0 Common Law/Statutory Arbitration 0 Declaratory Judgment 0 Mandamus 0 Non-Domestic Relations Restraining Order El Quo Warranto 0 Replevin El Other: ' PROFESSIONAL LIABILITY 0 Dental D Legal 0 Medical 0 Other Professional: Updated 1/1/2011 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY ESQUIRE ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 14- 045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. ` NO: y��ss3 t 1 l Krista L. Leach 329 Fulton Street Enola, PA 17025 DEFENDANT COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE 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 THIS 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 CLAIMED IN THE COMPLAINT OR 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 SHAPIRO & D NARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY 1D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 14- 045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL-DIVISION CUMBERLAND COUNTY VS. NO: Krista L. Leach 329 Fulton Street ; Enola, PA 17025 DEFENDANT i COMPLAINT IN- MORTGAGE FORECLOSURE Plaintiff, JPMorgan Chase Bank, National Association, the address of which is, 3415 4 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee Mortgage Electronic Registration Systems, Inc. as nominee for MNet Mortgage Corp., its successors and assigns Mortgagor(s) Krista L. Leach (b) Date of Mortgage July 14, 2011 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Document ID# 201119919 Date: July 18, 2011 The Mortgage js a matter of.public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A-true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for MNet Mortgage Corp., its successors and assigns Assignee: JPMorgan Chase Bank, National Association Date of Assignment: June 26, 2013 Recording Date: July 1, 2013 Instrument No.: 201321573 The Assignment(s) is /are a matter a matter of public record and are therefore incorporated herein as provided by Pa. R.C.P. No. 1019(g). 2. Plaintiff is either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property that is subject to the Mortgage is generally known as 329 Fulton Street, Enola, PA 17025 and is more specifically described as attached as part of Exhibit "A ". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Promissory Note "). A true and correct copy of the Promissory Note is attached and marked as Exhibit "B ". 5. The names and mailing addresses of the Defendants are: Krista L. Leach, 329 Fulton Street, Enola, PA 17025. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of October 1, 2013 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of February 12, 2014: Principal Balance Due $80,490.56 Interest Currently Due and Owing at 4.5% $1,509.20 From September 1, 2013 through January 31, 2014 Escrow Advances $93.37 Property Inspection $14.00 TOTAL $82,107.13 9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible under the Note and Mortgage. 10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ". 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Promissory Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO •& DeNARDO, LLC Date: , orneys for Plaintif CAITLIN M. DONNELLY, UME S & D File No. 14- 045139 t ROBERT P. ZIEGLER RECORDER OF DEEDS a� CUMBERLAND COUNTY 1 COURTHOUSE SQUARE _ CARLISLE, PA 17013 717 - 2406370 Instrument Number - 201119919 Recorded On 7/18/2011 Al 3:49.38 PM Tout Pages -10 • Instrument Type - MORTGAGE Invoice Number - 90132 User ID - KW • Mortgagor - LEACH, KRISTA L • Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC • Customer - PYRAMID LAND STATE WRIT TAX $ 0.5 0 Certification Page STATE JCS/ACCESS TO $23.50 JUCE RECORDI DO NOT DETACH RBCORDTNG FEES — $21.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is now part NZES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOT" PAID $72.00 I Certify this to be recorded in Cumberland County PA R�coRp�R a >u >us " - Information denoted by an asterisk may cbaRge durbag 01e Wificalion process and may not be renected on ah paga ���IIIIf��IlE�lrl�l i . MORTGAGE NETWORK, INC. 100 LARRABEE ROAD SOUTH WESTBROOK, MAINS 0 4092 0 03 ftec a Abovo This Un FOr Rewni ax Datal MIN , FHA Case No. �- -- - 2038 MORTGAGE THIS MORTGAGE ( "Security Instrument") is given on JULY 14, 2011 The mortgagor is KRISTA. L LEACH, SXNGLE ("Borrower "). This Security hum m i is given to Mortgage Electronic RcgisGrntion Systems, Inc, ("HERS "). M13RS is a separate corporation that is noting solely as a nominee for lender acid Lender's suoccwm and assigns. MERE is the mortgagee under this Securfty Inatmoaent, MFRS is organized and existing under the laws of Delaware, and has an address and telephone number of 1901 S. Voorhees Street, Suite C, Danville. IL 61834 or P.O. Box 2026, Flint, MI 48501- 2026, tai.' (888) 679 -WRS. MET MORTGAGE CORP, A CORPORATION which is organized and existing uudt:r the laws of THE COMMONWEALTH OF MASSACHUSETTS and whoseaddressis 300 ROSEWOOD DRIVIa, DANVERS, MASSACHUSETTS 01923 Borrower owes Louder the principal sum of EIGHTY- THREE THOUSAND THREE HUNDRED SIXTY -TWO AND NO 1100 Dollars (U.S S 83,362.00 ). This debt is evidenced by Borrower's note dated the same date as this Smut* Instrument ( "Note's, which provides for monthly payments, with the AM debt, if not paid earlier, dric and payable on AUGUST 1, 2041 , This Security Instrument mums to Lender; (a) the repayment of dw debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of aft other sums, with interest, advanced under Paragraph 7 to protect the security of this Security Inshlunent; and (a) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MRS (solely as nominee for Lender and bender's successms and assigns) and to the ' successors and assigns of MERS, the following described property located in CUMBERLAND County, Pennsylvania; LEGS DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF' whiohhasthcaddressof 329 FULTON STREET, ENOLA Pennsylvania 17025 "Pr 11 (City] ("Property Address"); (zip CDCW FUA Pcomylvan,. Msft a A44 FR"AMMO1.PM111 0 301 24.T6701 Pap t ore TOGETHER WITH DR the improvements now or hereafter erected on the property, and all easements, apps, and ftxturas now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." nderstand that WRS holds only legal title to the interests granted by Borrower in this S l t but, i sandagnps with law or custom, )AM (as nominee for Lender and Lender's succeam and assigas) has the right too exercise eny oatl of those interests, including, butnot Iimited to, the right to foreoloso and sell the Property; and to take any action required of ��_.. Lender including, but not limited to, releasing and oanceling this Security Instrument. "'�HDRRUWER COVENANTS that Borrower is Iawfuliy seized of the estate hereby conveyed and has the right to .mortgage, grant and convey the property and that the Property is unenauntbered, except for encumbrances of record, Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any etcumbreuces of record, THIS SECURITY INSTRUWNT combines uniform covenants fbr national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrtuutent covering deal property UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: x, Payment of Prinelpalp Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note, 2. Monthly payments of Taxes, Insurance and Other Charges, .Borrower shall include in each monthlypayment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (o) premiums for insurance required under Paragraph 4, In any year in which the Lender must pay a mortgage insurance premium, to the Secretary of Housing and Urban Development ( "Secretaty "), orin any year in which such premium would have been required if Lender salt held the Security Instrument, each monthly payment shall also include either: (i) a sum far the annual mortgage inffiu snce premium to be paid by bender to the Secretary, or (ii) a monthly charge insteadof a mortgage insurance pawn if this Security Ins4tancut is held by the Secretary, in a reasonable amount to be detarrainW by the Secretary. Exoopt hr the monthly charge by the Seer vq, those items are called "Escrow Items` and the sums paid to Lender are cal led "Bserow Funds." Leader may, at any tithe, oolleet and hold amounts for Escrow Items in an aggregate amountnot toexceed the maxmnan amount that may be required for Borrower's esarow account under the Real Estate Settlement Procedures Act of 1974,12 U.S.C. Section 2601.E eSM. and implementing regulations, 24 CFR Part 3 500, as they may be amended f ran time to time ('RESPA "), except that the cushion or reserve permitted by RESPA for unanticipated disbursements ordisbursements before the Borrower's payments are available in the account may not be based on amounts duefor the mortgage insurance prt sniutm. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender mall account to Borrower for the excess fbnds as required by RESPA. If the amounts of funds held by Leader at any time are not . stiff cient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to snake up the shortage as permitted by RESPA. The Esorow ftd.4+ are pledged as additional security for all stuns secured by this Security lostnunent If Borrower tenders to Lender the full p ayment of all such sums, Borrower's account shall be credited with the balance remaining for al I installment items (s), (b), and (o) and any mortgage - insurance premium installmeat thatItuder has not become obligated to 'pay to -the Secretary, and Lender shall promptly refund any excess Rinds to Borrower. Immediatoly prior to a foreclosure sale of the Property or•its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments, All payments under Paragraphs 1 and 2 shall be applied by Lender as follows: EiW, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage msurarxse premium; Secg�, to arty terries, special asseasments, leasehold payments or ground r =ts, and fire, flood and other hazard insurance premiums, as required; Third to interest due under the Note; r°tr>th. to amortization of the principal of the Note; and to lato charges due under the Note. NBA. ?"MAnnu Morlgege -o" FWAMEROXYRN -W19 30724.16901 FW2ora _._...... _ , _V.. ........1 ._.....,. 4. Fire # Flood and OtherRazard bsurance. Borrower•shall insure all Improvements oftho property, whethernow m existence or subsequently erected, against any hazards, casualties, and oontingenoies, inouding fire, for wluab Deader requires Insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Seoretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any wnowals shall be held by Lender and shall includo loss payable clauses in favor of; and In a form acceptable . _..... �_. _ tc7. _ 10 the event of loss. B otmower shall give Lender immediate notice by mail, Lender may makeproefof loss if not made promptly by Borrower. Bach insuranoo company concerned is hereby authorized and directed to make paymett for such loss directly to Lender, instead of to Borrower and to l cmdor jointly. All or anypari of the insurance proceeds maybe applied by Lender, at Its option, ei ther (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in Paragraph 3. and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of tho proceeds to the principal shall not extend or postpone the duo date of the monthly payments which are referred to in Paragraph 2, or change the amount of such payments. Anyexoess insuranoe proceeds over an amount required to pay all outstanding WeNedness under the Now and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that oxtinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Malatenance and Protection of the Propert Borrower's Loan Applieatlon; Leaseholds. Borrower shall occur, establish, and use the Property as Borrower's principal residenco wittuin shay days after the execution of this Seoxaity Instrmn=t (or within sixty days of a later sale ortr,3nsfer of the Property) and shall continuo to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, runless Lender determines that requiraneat will cause undue hardship for Borrower, or unless extenuating churnsta7 roes exist which are beyond Borrower's control. Borrower stall notify hander of any extetmsting circumstances. Borrowershall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abaudoned or the loan is in defrwlt. Lender may take reasonable action to protect and preserve such vacant orabandoned Property. Borrower shall also be in default ifBorrower, during the loan application process, gave materially false or inaccurate Information or statements to Lender (or failed to provide Lender with any material k6rmation) in connection with the loan evidenced by the Nate,.includiug, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence, if this Security Instrument is on a leasehold, Borrower snail comply wish the provisions of the lease. Borrower shall not surrender the leasehold estate and interests herein conveyed or terminato or cancel the ground lease. Borrower shall not, without the express written consort of Lender, alter or amead the ground lease. If Borrower acquires fee title to the property, the leasehold and fee title shall aotbe merged unless Leader agrees to the merger in writing. 6. Condemnations The proceeds of any award or claim for damages, direct or oonsequentiat,•in connection with any condemnation or other taking of any part of the Property, or far conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of tlx full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lbuder shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in Paragraph 3, and than topre wyment ofprincipal. 'Any application of the proceeds to the principal shall not extend or postpone the due date of the monthlypaymcuts, which are segerr ed to in Paragraph 2, or change the amount of such payments. Any excess prooceds over an amount required to pay all outstanding indebtedness under the Note mod this Security Instrument shall be paid to the entity legally entitled thereto. 1. M agrees to Borrower and Protection oMender's Rights In the Property. Borrower shall pay all govowu nUl or municipal charges; fines and impositions that are not included in Paragraph 2. Borrower shall pay these obligations on time directly to the entity which is'owed the payment. Lffailure to pay would edversely af]'eot Lender'sinterastiathePropeaty, upon Lendoes request Borrower shall promptly furnish to Lender receipts evidencing those payments. If Borrower fails to make thekc payments or the payments required by Paragraph 2, or fails to perform any other oovonants and agreements contained is this Security Instnune t, or there is a legal proceeding that may signiSeantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), thou Lender may do trod pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in Paragraph 2. PWAMIptOM"4I✓10 gp7R0.159a1 F%aaof$ Any amounts disbursed by bender under this Paragraph shall become an additional debt of Borrower aadbe sacutedby this -;c01tt'ity Instrument. 'These =OurAs shall bear interest from the date of disbuimn nt at the Note rate, and at the option o f Lender, Mall be immediately due and payable. Borrower shall promptly discharge any lien whioh has priority over this ScowityIrstrurrrantunless Borrower. (a)agrees in writing to the payment of the obligation secured by the lien in a mariner acceptable to Lender; (b) contests in good faith the lien by, or defends against enfonernent of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the Gen; or (c) accrues from the holder of the lien an agreement satisfactory to Lender subordinating the Been WO Inetrumont. If Lender determines that any part of the Property is subject to a Gen which may attain priority over this Security Instrument; lender may give Borrower a notice identifying the lien. Borrowcr shall satisfy the lien, or take one or more of the actions set forth above within 10 days of the giving of notice. t3- Rees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary in the osso of payment defaults, require immediate payment in hull of all sums scoured by this Security instrument it (i) Borrower defaults by failing to pay in full any monthly payment required by thus Security instrument prior to or on the due date of the next monthy payment, or (U) Borrower defaults by failing, for a period of thirty days, to perform any outer obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, Upermittod by applicable law ( including Section 341 (d) of the Oarn St, Oermain Depository Institutions Act of 1982, 12 U.S.C. 170li -3(d)) and with the prior approval of the Socretary, require immediate payment in ftrll of all sums secured by this Security Instrument If (i) All or part of the Property, or a bcn4cial interest in a trust owning all or part of the Property, is sold or otherwise tran4ferrod (other than by devise or descent), and (ii) Thn Property is not occupied by the ptirohaser or grantee as his or hor prinoipal residence, or the purchaseror Want= does no axsupy the Property, but his or her caedit has not been approved in accordance with the requirements of the Secretary. (e) No Waiver. If circumstances occurthat would permit Under to require immediatepaymentinfidl, but Lenderdoes not require suoh payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations of liM Secretary. In many circumstances regulations issued by the Seomtary will limit Lender's rights, - in the case of payment defaults, to require immediate payment In N and foreclose if pat paid This Security Instrument does not authorrze acceleration or foreclosure if not permitted by regulations of the Secretary_ (e) Mortgage Not Insured. Borrower agrees that if this SecuriV Instrument and the Note are not determined to be eligible for insurance under the Naderial Housing Act within 6 day,9 from the date 4ereoi; Lendermnay, at its option, require immediate payment in Mull of all arms geum4 by this Security Instrument. A written statement of oy authorized agent of the Secretary dated subsequent to 6 o ttaYS $nm the date hereof, declining to Insure this Security Instrument and theNoto, shall be deemed conclusive proof ofsuch ineligibility. Notwithstan ding ew f6re0oing, this option may not be axercis+ed by Leader whorl the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. ReinstataoscnL Boxrowerhas aright to be reinstated ifLcnderhas required immed[Wepsymmt in ctrl! beoauseof Borrowe'sfailum to per an amount due under the Note or this Security Instrument This right applies even after• foreolosure prdceeclings are instituted. 'fo reinstate the Security Instrument, Borrower shall tender in a lturip gum all anrountsrequuired to bring Borrower's account oii rent including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable, and customary attorney's fees and exp=aes properly associated with the foroolosure proceediug. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall rernain in eft'ect as ifLendcrhad not required immediatepayment um full. However, Lender is not required to pwnkreinsmterricat if' (i) Lender has accepted minstaternent after the commencement of foreoiosure proceedings within two years immediately preceding the commencement ofa current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on di want grounds in the future, or (iii) reinstatement will adversely affect the priority of thelienoreated by this Security instrument runs nr�t�.�� nt�a�roo ir1APAL(a0. 1. IN 30724.16901 Pap4af9 11- Borrower Not Itolemed; Forbearance By Lender Not a Waiver. Extension of the turn of payment or modification of amortizati on of the sums secured by this Security Instrument granted by Lender to any successarin interest of Borrower shall not operate to release the liability of the original Borrower or Borrower`s aucoessor in interest. Lender shall not be required to commence proceedings against any successor in inter g or refbse toextend time for payment or otherwise modify amortization of the sums woured by this Security lostrument by mason of any demand made by the original Harrower or Borrower's suoeessors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiverof or preclude the exercise of any right or remedy. — I'2.. Successon and Assigns Bound; Joint and Several Liability; Co,Slgaem Il000veamts and agreements ofthis Security Instrument shall bind and benefit the successors and assigns of Lender and'Bon subjeot to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co -signs this Security Instrument but does not execute the Note: (a) is oo- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the teamsof this Security Instrument; (b) is not personallyobilgated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrowermay agree to extend, muddy, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Notieee. Any notice to Borrower provided for in this Security Instrument abaft be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given byfrrst chess mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any noticeprovided fur in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Sevetrabilfty, This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the property is located. In the event that any provision or clause of this Security Instrument or the Note oontlicts with applicable low, such conflict shall not affect other provisions of this Seourity Instrument or the Notewhich can be given affect without the oonflloting provision. To this end rho provisions of this Seourity Instrumant and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Mote and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the promos, use, disposal, storage, or releasoofany Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two se ntenoes shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to•beappropriateto nonval rosidanoal uses and to maintenance ofthe Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency orprivete party involving the Property and any Hazardous Substance or Envlrorumental Law ofwhioh Borrower has actuallrnowledge. If Borrower locum, or is notified by any governmental or regulatory authority, that any removal or other remedistion of any Hazardous Subst mnccs affecting the Property is neoas'sary. Borrower shall promptly take all necessary remedial actions in a coonlance with Environmental Law. As used in this Paragraph• 16, giasrdous Substanoes° are those substances defined as toxic orharardous substances by Environmental Law and the following substances: gasoline, kerosene, other Aammable or toxic petroieta products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldebyde, and radioactive materials. As used in this Paragrapb 16,'Environmental Law° means federal laws and laws of eke jurisdiction where ft property is located that relate to healthy, safety or environmental protection. NON. UNIFORM COVFNANTS. Borrower and Lender further covenant end a#= as follows: 17, Assignment of Rohta Borrower unconditionally assigns and transfers to Lender at] there uts and revenues oftbe Property. Borrower authorizes Lender orLendees agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach • of any covenant br agreement in the Security Instrument, Borrower shall collect and reeeive'all rents and rove rues of the property as trustee for the benefit ofLender and Borrower. This assignment of rents constitutes an absolute assignment and not sn assignment for additional security only. If T ender gives notice ofbreaoh to Borrower: (a) all rents received by Borrower shall be held byBorrower as to dw fbr benefit of Lender only, to be applied to the aums secured by the Security Instrument, (b) Lender shall be ontitled to collect and receive all of the rents of the Property; and (c) cash tenantof the Property shall pay all rents due and unpaid to Leander or Lenders agent on Lcrrdor :s written demand to the tenant. YHA Pen +96 nrylvdr�h Mo"gase -6 Voaa sofa FILNPAMBROS.VRN.H110 3072/.16gM1 1 Borrower has not executed any prior auipntnent of the rents and has not and will not perform any act that would proveat Lender from exercising its rights under this paragraph 17. Lender •shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower, However, Leader or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure orwaive any default or invalidate any other right or remedy of Lender, This assignmentof rents of the Properly shall terminate when the debt scoured by the Security Instrument is paid in full. 18, Foreclosure Procedure. IfLender requires immediato payment in fell under Paragraph 9, Lender may 'Wv'a�an rremedies perm#ted by applicable law, including, but not by way of limitation, foreclosure of this Security Instrument by judielal proceeding. Lender shop be entitled to collect all expenses incurred in punuhngthe remedies provided In this Paragraph 18, latdudi ig, but not limited to, attorney's fees and coats oftitle evklance to the extent permitted by applicable law. If the Lender's interest In this Security Instrument Is held by the Secretary and the Secretary requires immediate payment in full anderParagraph 9, the Secretary way invoke the tionjudicial poorer of sale provided in the Single Fancily Mortgage Foreclosure Act of 1994 ( "Act ") (12 U,S,C, =1 e1 US) by requesting a foreclosure commissioner designated under the Act to oommenee foreclosure and to eel the Property as provided in the Aet- Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a bonder under this Paragraph 18 or applicable law. 19. Release, Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, bender shall discharge and satisfy this Security Instrummi. Borrower shall pay any recordation costs. Lender may change Borrower a fee for releasing this Socurity Instrument, bus only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under applicable law. 20. Waivers, Borrower, to the extent permittod by applicable low, woive and releases any error of defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of my prescrrtorfutum laws providkg%r stay of execution, oxtension of time, exemption from attachment, levy and sale. and homestead exemption. 21, Reinstatement Period, Borrower's time to reinstato provided in Paragraph 10 drall extend to one hour prior to the commencement of bidding at a sheriffs sale or other We pursuant to this Security Instrrmront. 22. Purchase Money Mortgage. If any of the debt secured by this Seourity Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase moneymortgage. 23, Interest, Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an aotion of rhortgage foreclosure shaU be the rate payable firm time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Insbument, the covenants and agreements of each shah rider shall be incorporat,6d into and shall amend and supplement the oovenants and agreements of this Security Instrument as if the rider(s) were a part of this Smmirity Instrument (Cheek applicable box(cs)J Condominium Rider Graduated Payment Rider t3rowing Bgtuty Rider Planned Unit Development Rider X Adjustable Rate Rider ReshabilitationLomtRider Nan -Owner Geoupanoy Rider O�� CACHED mttacennryt..rs. niors8.��a . PWAMEM.Pk IM0 30724.16901 P4460r3 BY SIGNING BELOW, Borrower accepts and agrees to tho terms and covenants contained in this Secmitylnstivuient and in any rider(s) executed by Borrower and recorded with it. Witnesses; (.Seal KRISTA L - Borrower - Borrower (Seal) (Sea!) - Borrower - Borrower (Seal) (Seal) -Borrower - Bom)wer CERTIFICATE OF RESIDENCE. I, the undersigned subscribing Agent of the Lender named within, do hereby certify that the oonvot address of the said Lender is MNET MORTGAGE CORP, 300 ROSEWOOD DRIVE, DANVERS, MASSACHUSETTS 05923 WITNESS MY HAND Ibis /' j� day of S `�x Agent of Lender PdzW Name FrLA Perm:ylvaola MoKg�at 6f96 FHAFALEE1907YRN -11110 30724.16901 PW 7 M „ [Space Below Thb Line )~'or Admowhigemeot COMMONWEALTH OP Pl NNSYLVANU, OA county ss; On this, the 1 41<h day of a'M , 2 011 before me, the undersigned officer, personeliy appeared KRTS.TA. L LE ACH known to me (or satidoototily proven) to be the person(s) whose names) is/are subscribed to the within instruamt and acknowledged that helsheacy executed tllo same for the purposes herein contained. IN WnMSS WRMOF. I hereunto set my hand and official seal. My commission expires: C+ Title officer C t# NWiALTH oP PE =$ta9l,,Notary YLVANJ SIAL Notary pubtlo m0'Itry County as June 07, 2016 YHA PtnruyhnWs Mortq�ga6/96 IMAPAMEROORN•11AG 50724.10001 Peeaicr8 a Exhibit A ALL THAT CERTAIN LOT or piece of ground situate in East Penesboro Township, Cumberland County, Pennsylvania, with the dwelling house erected thereon, more particularly bounded and descrJbed as follows, to wit: BEGINNING at a point two hundred ulnety -seven and ten one hundredths (297.10) feet from the northwest corner of Fulton and Zion Streets, at the corner of Lot No. 24 on the hereinafter mentioned Plan of Lots; THENCE along line of Lot No. 24 in a northerly direction, sixty -six and sixty -seven one hundredths (66.67) feet to a point; THENCE in an easterly direction and parallel with Fulton Street, Jifty (50) feet to a point on the line dividing Lots Nos. 25 and 26 on said plan; THENCE in a southerly direction along said line dividing Lots Nos. 26 and 26, sixty -six and sixty -seven one hundredths (66.67) feet to a point on the lime of Fulton Street; THENCE along the line on Fulton Street, in a westerly direction, fifty (50) feet to a point, the place of BEGINNING. BEING THE southerly sixty -six and sixty -seven one hundredths (66.67) feet of Lot No. 25 on Plan #2 of Hoopy's Addition to the town of Inola, said Plan beiug recorded In the Recorder of needs Office for the County of Cumberland, at Carlisle, Pennsylvania in Plan Book 1, Page 7. BEING the same premises which David A. Lloyd and Sandra J. Lloyd, his wife, by deed dated August 22, 1989 and recorded on August 24, 1989 in the Office of the Recorder of Deeds in and for the Cumberland, County, Pennsylvania In Deed Book D 34, Page 44, granted and conveyed -unto David A. Lloyd, Grantor, herein. r e / NOTE MIN - xA CA No. LOAN NO. JULY 14, 2MI CARLISLE, PENNSYLVANIA [Date) 329 FULTON STREET, ENOLA, PENNSYLVANIA 17025 [Property Address) 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Under" means MNET MORTGAGE CORP, A CORPORATION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of EIGHTY-THREE THOUSAND THREE HUNDRED SIXTY-TWO AND NO/ 10 0 Dollars (U.S. $ 83,362. 0 0 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at a rate of FOUR AND ONE / HALF -- - - - - percent( 4 .500 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the 1st day of each month beginning on SEPTEMBER 1, 2011 . Any principal and interest remaining on the 1st day of AUGUST, 2041 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 300 ROSEWOOD DRIVE, DANVERS, MASSACHUSETTS 01923 or at such other place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U. S. $ 4 2 2 .3 8 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument hereof. (D) Allonge to this Note for Payment Adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of thisNote. [Check applicable box] El Growing Equity Allonge ❑ Graduated Payment Allonge ❑ Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 30724.15901 MULTISTATE FRA Fixed Rate Note - ` «� FHA14864.Plul -6108 Pop 1 o12 BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of f our percent( 4. 0 0 a /o) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its nights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment infull in the case ofpsyment defaults. This Note does not authorize acceleration when notpermitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the night to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. Vj haaL � (Seal) (Seal) KRTSTA L LEACH - Borrower Borrower (Seal) (Seal) - Borrower - Borrower E Ai!ff (Seal) (Seal) II 651otant - Borrower - Borrower Without Pe Way to the Re course JP JP M o rgan C hase Barli;, NA oourse MNET Mortgage Corporation, A Corporation 30724.15901 MMnSTATE FHA Fixed Rate Note - r WSW FHAM4MYRN -6108 P C Chad M. Goodwin Pipeline Manager P.O. Box 183205 Columbus, OH 43218 USPS CERTIFIED Mp,IL TM For Undeliverable Mail Only 9214 8901 0754 4631 1395 39 019800-1 of 4 NSPOHDI A-CA /0462352 0000000 KRISTA L LEACH 329 FULTON ST ENOLA PA 17025 c r a Chase (OH4 -7399) CHASE ! i P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only 12/02/2013 KRISTA L LEACH 329 FULTON ST ENOLA, PA 17025 NOTICE OF INTENT TO FORECLOSE MORTGAGE Account: � (the "Loan ") Property Address: 329 FULTON ST ENOLA, PA 17025 (the "Property") Dear KRISTA L LEACH: Under the terns of the Mortgage or Deed of Trust ( "Security Instrument ") securing your Loan, JPMorgan Chase Bank, N.A.( "Chase "), as servicer of your loan, hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 10/01/2013 for the mortgage held by JPMorgan Chase Bank, National Association. 2. As of 12/02/2013, 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 $1,267.38 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 $1,253.38 Late Fees $0.00 NSF Fees $0.00 Other Fees and Advances* $0.00 Advances* $14.00 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. Certified Article #: 9214 8901 0754 4631 1395 39 019800.2 of 4 NSPOHDLA -CA J0462352 0000000 4 You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 01/04/2014 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 and you may lose the chance to pay off the original mortgage in monthly installments. 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. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the 33-day period, you will not be required to pay attorney's fees. 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 01/04/2014, 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 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. 7. If permitted 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, if permitted by law, related to any foreclosure action we initiate. Certified Article #: 9214 8901 0754 4631 1395 39 4 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 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. 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 -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 Certified Article #: 9214 8901 0754 4631 1395 39 019800 - 3 of 4 NSPOHDLA -CA J0462352 0000000 r i, 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. BR840 Certified Article #: 9214 8901 0754 4631 1395 39 Sri 3,. portant.rne s tai frorn the Federal Trade c:::cJrr�rni � on >' Facing foreclosure? Stammers 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, "97% success rate!" and websites to make it look like they're part "Guaranteed to save your home!" of the government. If you want to contact a These kinds of claims are the tell -tale signs of government agency, type the web address a foreclosure rip -off. Steer clear of anyone directly into your browser and look up any who offers an easy out. address you aren't sure about. Use phone numbers listed on agency websites or in other Don' Pay for a Promise. reliable sources, like the Blue Pages in your Don't pay any business, organization, or phone directory. Don't click on links or open person who promises to prevent foreclosure or any attachments in unexpected emails. get you a new mortgage. These so- called "foreclosure rescue companies" claim they Talk to a HUD - Certified Counseling can help save your home, but they're out to Agency - For Free make a quick buck. Some may request hefty If you're having trouble paying your mortgage fees in advance — and then stop returning your or you've already gotten a delinquency notice, calls. Others may string you along before free help is a phone call away. Call 1- 888 -995 disclosing their charges. Cut off all dealings if -HOPE for free personalized advice from someone insists on a fee. housing counseling agencies certified by the U.S. Department of Housing and Urban Send Payments Directly. Development (HUD). This national hotline — Some stammers offer to handle financial open 24/7 — is operated by the arrangements for you, but then just pocket Homeownership Preservation Foundation, a your payment. Send your mortgage payments nonprofit member of the HOPE NOW ONLY to your mortgage servicer. Alliance of mortgage industry members and HUD- certified counseling agencies. For free Don' Pay for a Second Opinion. guidance online, visit www.hopenow.com. Have you applied for a loan modification and For free information on the President's plan to been turned down? Never pay for a "second help homeowners, visit opinion." www.makinghomeaffordable.gov. t i,si rf f[c.90 � /11rieyNlattrr� Certified Article #: 9214 8901 0754 4631 1395 39 019800 - 4 of 4 NSPOHDLA -CA J0462352 0000000 it +b 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.ho p enow.com For free information on the President's plan to help homeowners, visit www. makin homeaffordable. ov g g . �crp {fafS- x�crc�ane. crWbmeuwaer.., MAKING OE ATT ALE GO Certified Article fs: 9214 8901 0754 4631 1395 39 r i Pennsylvania Verification Antonio Croom , 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. Antonio Croom Vice President Date: 03/07/14 JPMorgan Chase Bank, N.A Borrower: KRISTA L LEACH Property Address: 329 FULTON ST ENOLA PA 17025 County: Cumberland Last Four of Loan Number: 4755 FORM 1 : IN THE COURT OF COMMON PLEAS OF JI'Morgan Chase Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) C'_ vs. j �'ry; ':� Krista L. Leach 329 Fulton Street Enola, PA 17025 SS T;' C-') � � DEFENDANT Defendant(s) Civil 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. r Respectfully submitted: SHAPIRO & DeNARDO, LLC Date Wttorneys for Plaintiff CAITLIN M. DONNELLY, ESQUME 1 r FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C Mailing Address: City: State: Zip: Phone Numbers: Home: Office: i Cell: Other: Email: # of people in household How Long? FINANCIAL INF ORMATIO N 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: Primaa Reason for Default: Is the Loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile 41: Model: Year: Amount Owed: Value: Automobile #2: Model: Year: 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 a in EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No 0 If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 i 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 ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating in 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 Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 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) : FORM 3 IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Krista L. Leach 329 Fulton Street Enola, PA 17025 DEFENDANT Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) Vs. Defendant(s) Civil CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (2 1) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. t 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Defendant(s) Civil 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Re ectfully submitted: Date Sigfiature of Counsel for PI tiffl CAITLN DONWELLY, E L Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/PRIMARY Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C O-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FINANCIAL INF ORMATIO N First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes ❑ No ❑ If 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 Owed: Value: Automobile #2: Model: Year: 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 Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 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 ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: O. I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating in 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 Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 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) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY or( cm*�� '�—HE PROTA040���� 28111 � "P� -� PM �� � ._ � - ��� CUMBERLAND PENNSYLVANIA ���em+��x»swp ~~' '~ ^ COUNTY JPMorgan Chase Bank, National Association vs. Krista L Leach Case Number 2014-1553 SHERIFFS RETURN OF SERVICE 03/24/2014 05:20 PM Deputy D 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: Krista L Leach at 329 Fulton Street, East Pennsboro, Eno|o, PA 17025. DAWN KELL, DEPUTY 03/24/2014 05:20 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 329 Fulton Street, East Pennsboro, Enola, PA 17025. Per defendant Krista L. Leach there are no other occupants. SHERIFF COST: $54.95 SO ANSWERS, March 25, 2014 RONNYR ANDERSON, SHERIFF (c) CountySuife Sheriff. 'releaser:, inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment , . . ( ) Other , i , ri JPMorgan Chase Bank, National Association File No. it/ - Lit' I PLAINTIFF Amount Due $85,206.29 c.: ( Interest June 1, 2014 to December 3,a141,,I is $1,953.93 1 vs. Atiy's Comm Costs Krista L. Leach DEFENDANT(S) TO THE PROTHONOTARYOF THE SAID COURT: " rn 1-1-1 --.*7--"-) --, c -i - -p. 2- .--A .....1 ---+ , +4. The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it doe's, it is based on the appropriate original proceeding filed , pursuant to Act 7 of 1966 asamended; and for real property pursuant to Act 6 of .1974 as amended. . . . Issue writ of execution in the al bove matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s), 7 See attached Leda' Description PRAECIPE FOR AtTACHEMENtECUTION- , Issue writ of attachment to theSheriff of Cumbeiland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pen defendant(s) described in the attached exhibit. bA"k. Date: Signature: `vallw Print -Name: a ens against real estate of the Osborne Address: .00 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 312169 (5/ h3SSve- JPMorgan Chase Bank, National Association 3415 Vision Drive Columbus, OH 43219 Cumberland County Redevelopment Authority 114 North Hanover Street Suite 103 Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 329 Fulton Street Enola, PA 17025 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. BY: 14-045139 SHA IRO & DeNARDO, LLC eyJ Osborne SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF VS. Krista L. Leach DEFENDANT CIVIL DIVISION CUMBERLAND COUNTY NO: 14-1553 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Krista L. Leach 329 Fulton Street Enola, PA 17025 Your house (real estate) at: 329 Fulton Street, Enola, PA 17025 09-14-0834-119 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $85,206.29 obtained by JPMorgan Chase Bank, National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1 The sale will be cancelled if you pay back to JPMorgan Chase Bank, National Association the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may 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 on page two of how to obtain an attorney.) 4. C; YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 14-045139 ALL THAT CERTAIN LOT or piece of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, with the dwelling house erected thereon, more particularly bounded and described as follows, to wit: BEGINNING at a point two hundred ninety-seven and ten one hundredths (297.10) feet from the northwest corner of Fulton and Zion Streets, at the corner of Lot No, 24 on the hereinafter mentioned Plan of Lots; THENCE along line of Lot No. 24 in a northerly direction, sixty-six and sixty-seven one hundredths (66.67) feet to a point; THENCE in an easterly direction and parallel with Fulton Street, fifty (50) feet to a point on the line dividing Lots Nos. 25 and 26 on said plan; THENCE in a southerly direction along said line dividing Lois Nos. 25 and 26, sixty-six and sixty-seven one hundredths (66.67) feet to a point on the line of Fulton Street; THENCE along the line on Fulton Street, in a westerly direction, fifty (50) feet to a point, the place of BEGINNING. BEING THE southerly sixty-six and sixty-seven one hundredths (66.67) feet of Lot No,. 25 on Plan #2 of Hoopy's Addition to the town of Enola said Plan being recorded in the Recorder of Deeds Office for the County of Cumberland, at Carlisle, Pennsylvania in Plan Book 1, Page 7. BEING known and numbered as 329 Fulton Street, Enola, Pennsylvania PARCEL No. 09-14-0834-119 BEING the same premises which David A. Lloyd and Ruth Ann Geer -Lloyd, husband and wife, by Deed dated July 8, 2011 and recorded July 18, 2011 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201119918, granted and conveyed unto Krista L. Leach, single woman. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. KRISTA L. LEACH WRIT OF EXECUTION NO 14-1553 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: $85,206.29 L.L.: 5.50 Interest JUNE 1, 2014 TO DECEMBER 3, 2014 IS $1,953.93 Atty's Comm: Due Prothy: $2.25 Atty Paid: $203.71 Other Costs: Plaintiff Paid: Date: 6/11/14 Ia4AZCLI .LtALL (Seal) REQUESTING PARTY: Name: BRADLEY J. OSBORNE, ESQUIRE Address: SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 312169 David D. Buell, Prothonotary : 4w,lozezzty---- Deputy BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78441f3A CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 SHAPIRO & DeNARDO, LLC CUM PE pf t,i1A • r A C n 01' I, fel IC: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Krista L. Leach DEFENDANT NO:14-1553 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $85,206.29 in favor of the Plaintiff and against the Defendant, jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid Interest Accrued Late Charges Escrow Advances Property Inspection Attorney Fees & Costs of Foreclosure TOTAL . OSISORNP.,, EsQuIREAttorney for Plaintiff AND NOW, judgment is entered in fa or o aintiff anhtgain e • ant and damages are assessed as above in the sum of $85,20s 9.. I $80,490.56 $2,716.56 $0.00 $674.42 $56.00 $1,268.75 $85,206.29. 14-045139 A Pro . • r ouktl- 6) IP 56 itt44 C igoactisy Al e ma:/el SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS 3415 Vision Drive CUMBERLAND COUNTY Columbus, OH 43219 PLAINTIFF 14-1553 Civil VS. Krista L. Leach DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Date: 14'01/y BY: Sworn to and subscribed before me this 6 day SHAPIRO & DeNARDO, LLC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Sharkey, Notary Public Upper Merion Twp., Montgomery County My Commission Expires Oct. 19, 2014 Member. Pennsylvania Association of Notaries Department of Defense Manpower Data Center Results as of : Jun -10-2014 04:59:29 AM SCRA 3.0 Status Report Pursuant to Satvicemembers Civil Relief Act Last Name: LEACH First Name: KRISTA Middle Name: L. Active Duty Status As Of: Jun -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 reflevtstbe individuals' active duly status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - . NA - r 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 m _ / 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, NOM, 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. YA. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 60140.- The)efense 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: OA9BG947GODAMOO SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY 1.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY LD. NO, 312169 CHANDRA M. ARKEMA, ATTORNEY LD. NO. 203437 3600 HORIZON DRIVE, SUITE. 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association1 COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY vs. NO: 14-1553 Civil Krista L. Leach DEFENDANT CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was, mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, May 23, 2014 to the following Defendants: Krista L. Leach, 329 Fulton Street.Enola, PA 17025 Qz a4415a Meghan William, Legal Assista to Christopher A. DeNardo, Esqui. Shapiro &DeNardo, LLC 'SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY LD. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. Krista L. Leach DEFENDANT NO: 14-1553 Civil NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Krista L. Leach DATE OF NOTICE: May 23, 2014 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association •32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. , NOTIRCACION IMPQRTANTIF Usted se encuentra en estado de rebeldia por no haber tornado 1a accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacian, el tribuna podra, sin necesidad de compararecer usted in cone o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si listed no tiene abogado o si no tiene diner° suficiente para tal servicio, vaya en persona o llame por telefono la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 117013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Krista L. Leach, 329 Fulton Street, Enola, PA 17025 Date; BY: SHAPIRO &DeNARDO, LLC cys for Plainti OSSZ.V.N1.1., SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Krista L. Leach DEFENDANT NO:14-1553 Civil CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Krista L. Leach, 329 Fulton Street, Enola, PA 17025 Date Mailed: Date: BY: SHAPIRO & DeNARDO, LLC 6 ,A11 dry. neys for Plaintiff oetr 3. 0B010173, ESQuiR13 ." SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Krista L. Leach DEFENDANT NO:14-1553 Civil CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: JPMorgan Chase Bank, National Association 3415 Vision Drive Columbus, OH 43219 and that the last known address of the judgment debtor (Defendant) is: Krista L. Leach 329 Fulton Street Enola, PA 17025 Date: 14-045139 BY: SHAPIRO & DeNARDO, LLC rneys for Plaintiff BRArL iC J. OSBORNE, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Krista L. Leach 329 Fulton Street Enola, PA 17025 JPMorgan Chase Bank, National Association PLAINTIFF VS. Krista L. Leach DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-1553 Civil NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278-6800. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447- BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 3.12169 CHANDRA M. ARKEMA, ATTORNEY I.D.. NO. 203437 LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. Krista L. Leach DEFENDANT NO: 14-1553 Civil PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on June 11, 2014 in the above entitled action vacated without prejudice to Plaintiff. Date: (1141(1.1 BY: SHAPIRO & DeNARDO, LLC Attorneys for Plaintiff CHRISTOPHER A. DeNARDO, ESQ. Oskk-k gq.sopJ C 10 No;?&6 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-1553 Civil Krista L. Leach DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Vacate Mortgagec'f Foreclosure Judgment on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Krista L. Leach 329 Fulton Street Enola, PA 17025 Date: c(lVkA BY: SHAPIRO & DeNARDO, LLC Attorneys for Plaintiff CHRISTOPHER A. DeNARDO, ESQ. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 7844T: BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. Krista L. Leach DEFENDANT NO: 14-1553 Civil PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. Date: hittH BY: SHAPIRO & DeNARDO, LLC • Attorneys for Plaintiff CHRISTOPHER A. DeNARDO, ESQ. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 SARAH K. McCAFFERY, ATTORNEY I.D. NO.311728 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045139 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-1553 Civil Krista L. Leach DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on (1'4 �'( to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Krista L. Leach 329 Fulton Street Enola, PA 17025 Date: n, �� � BY: • SHAPIRO & DeNARDO, LLC • Attorneys for Plaintiff CHRISTOPHER A. DeNARDO, ESQ.